Homeland Emergency Preparedness and the National Exercise Program: Background, Policy Implications, and Issues for Congress

Homeland Emergency Preparedness and the National Exercise Program: Background, Policy Implications, and Issues for Congress

Order Code RL34737
Homeland Emergency Preparedness and the
National Exercise Program: Background, Policy
Implications, and Issues for Congress
November 10, 2008
R. Eric Petersen, Coordinator and Bruce R. Lindsay
Government and Finance Division
Lawrence Kapp
Foreign Affairs, Defense, and Trade Division
Edward C. Liu; David Randall Peterman
American Law Division; Resources, Science, and Industry Division

Homeland Emergency Preparedness and the National
Exercise Program: Background, Policy Implications,
and Issues for Congress
Summary
An emergency preparedness and response program provides resources and
support to individuals and communities that might be affected by a broad range of
disruptive incidents. These incidents may be caused by natural phenomena such as
severe weather, fires, earthquakes, tsunamis, or disease outbreaks. Incidents might
result from human activity as well, and could include accidents, criminal acts,
terrorism, or other attacks. Concerns have been raised whether current preparedness
and response policies and capacities are sufficient.
The effectiveness of preparedness doctrine may be demonstrated through
responses to real incidents, or through exercises that practice and refine responses to
a variety of potential disruptions. Exercises might demonstrate that responders have
the capacity to respond effectively to an incident, or identify areas in which
improvement is necessary. Lessons learned from an exercise may provide insights
to guide future planning for securing the nation against terrorist attacks, disasters, and
other emergencies. More broadly, emergency preparedness exercise programs may
provide insights about the efficacy of the government policies establishing
responsibilities within agencies, and whether those policies, organizational structures,
and processes adequately ensure the safety and security of public institutions, critical
infrastructures, and American citizens.
Current homeland emergency preparedness exercises, carried out through
authorities that created the National Exercise Program (NEP), evaluate and adapt an
integrated, interagency federal, state, territorial, local, and private sector capability
to prevent terrorist attacks, and to rapidly and effectively respond to, and recover
from, any terrorist attack or major disaster that occurs. This report, which will be
updated as warranted, provides an overview of emergency preparedness authorities
and guidance; development and management of the NEP; and current exercise
planning, scheduling, and evaluation processes. Additionally, it provides analysis of
national preparedness policy issues and exercise operations issues that Congress
might wish to consider. Legal authorities to conduct national level exercises and
preparedness exercises in general are provided in Appendix A. Since homeland
preparedness activities are typically addressed by planners and practitioners who use
specialized terms and abbreviations, Appendix B lists all acronyms used in this
report together with their meaning.

Contents
Policy Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Emergency Preparedness Authorities and Guidance . . . . . . . . . . . . . . . . . . . . . . . 3
Post-Katrina Emergency Management Reform Act . . . . . . . . . . . . . . . . 3
E.O. 12656 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
HSPD-8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Preparedness Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Toward a “National” Exercise Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
National Exercise Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
NEP Management and Coordination . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
NEP Requirements for Federal Executive Agencies . . . . . . . . . . . . . . 10
NEP Exercises . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
NEP Exercise Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Exercise Scheduling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
DOD Participation in the National Exercise Program . . . . . . . . . . . . . . . . . 15
Role of DOD in NEP Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
National Guard Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Exercise Development and Implementation Guidance . . . . . . . . . . . . . . . . . . . . 18
Exercise Planning: The HSEEP Method, Volume II . . . . . . . . . . . . . 21
Exercise Evaluation: The HSEEP Method, Volume III . . . . . . . . . . . . 22
DOD Exercise Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
National Guard Exercise Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . 25
Discussion and Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
National Preparedness Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Implementing Preparedness Exercise Programs: Which Authority? . . 27
Implementing Preparedness Exercise Programs: Which Officials? . . 28
State, Territorial, Local, and Tribal Participation in the NEP . . . . . . . 28
Private Sector Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
Evaluating NEP Progress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
National Exercise Simulation Center . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Communicating Preparedness Policy . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Congressional Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Exercise Findings Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Surge Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Interstate Movement of Commercial Emergency Response Vehicles . 34
Exercise Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
Exercise Realism . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
No-Notice Exercises . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Scale and Scope of Exercises . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Exercise Fatigue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
Evaluating Exercises . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
How “National” Is the NEP? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
NEP Opportunity Costs for Existing Agency Exercise Activities . . . . 40

Appendix A. National Level Preparedness Exercise Mandates . . . . . . . . . . . . . 42
Appendix B. Acronym Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
List of Tables
Table 1. Express Mandates to Conduct “National Level
Preparedness Exercises” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
Table 2. General Mandates to Conduct Exercises . . . . . . . . . . . . . . . . . . . . . . . 43

Homeland Emergency Preparedness and
the National Exercise Program: Background,
Policy Implications, and Issues for Congress
Policy Background1
An emergency preparedness and response program provides resources and
support to individuals and communities that might be affected by a broad range of
disruptive incidents. These incidents may be caused by natural phenomena such as
severe weather, fires, earthquakes, tsunamis, or disease outbreaks. Incidents might
result from human activity as well, and could include accidents, criminal acts,
terrorism, or other attacks. The scope of an incident could vary from a highly
localized disruption to a regional or national catastrophe. The duration of response
and recovery operations may be as short as a few days, or last for years. Federal,
state, territorial, local, and tribal levels of governments, as well as private sector
actors, could respond to an incident, either through on-scene response, or the
provision of resources and support. Multiple agencies within each level of
government are likely to contribute to a response, particularly when confronted with
a catastrophic incident.
Concerns have been raised whether current preparedness and response policies
and capacities are sufficient.2 Broadly, the effectiveness of preparedness doctrine
may be demonstrated through responses to real incidents,3 or through exercises that
1 This report is based in part on materials prepared at the request of the Senate Committee
on Homeland Security and Governmental Affairs, which the committee released for general
distribution to Congress. William M. Knight, formerly National Defense Fellow in the
Foreign Defense and Trade Division, authored sections of this report. Jennifer Manning,
Information Research Specialist in the Knowledge Services Group, provided research
support. William J. Krouse, Specialist in Domestic Security and Crime Policy, Domestic
Social Policy Division, provided technical assistance.
2 See Christine E. Wormuth and Anne Witkowsky, Managing the Next Domestic
Catastrophe: Ready (Or Not)? (Washington: Center for Strategic and International Studies,
2 0 0 8 ) , a v a i l a b l e a t [ h t t p : / / w w w . c s i s . o r g / m e d i a / c s i s / p u b s /
080909_wormuth_managingcatastrophe_web.pdf].
3 As with exercises, an incident might demonstrate the level of preparedness of federal, state,
territorial, local, or tribal responders, and provide an opportunity for those responders to
refine their actions based on their experiences. See for example, U.S. Senate, Committee
on Homeland Security and Governmental Affairs, Hurricane Katrina: A Nation Still
Unprepared, 109th Cong., 2nd sess., S.Rept. 109-322 (Washington: GPO, 2006); Monica
Giovachino, Elizabeth Myrus, Dawn Nebelkpof and Eric Trabert, Hurricanes Frances and
Ivan: Improving the Delivery of HHS and ESF#8 Support (Alexandria, VA; CNA
(continued...)

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practice and refine responses to a variety of potential disruptions. Exercises to test
the potential efficacy of operational plans, civil assistance, or domestic emergency
management response have long been a component of military training and civilian
domestic preparedness efforts. Numerous exercises at the national, state, territorial,
local, and tribal levels of government, as well as by the private sector, are carried out
almost daily.4 Among potential benefits, exercises might identify deficiencies in
response plans that can be addressed before an incident occurs. Specifically,
exercises might be employed to
! validate the effectiveness of response plans for various kinds of
incidents or emergencies;
! identify or refine response capacities of federal, state, territorial,
local, tribal government and private sector entities;
! assure participation of senior government leaders to familiarize them
with the preparedness functions of their positions;
! integrate civilian homeland security response with military
homeland defense and support to civil authority missions;
! permit personnel from various federal agencies to become
acquainted with the other, and with their counterpart officials in
state, territorial, local, and tribal government, so as to enhance
coordination and cooperation;
! test and evaluate knowledge and training of exercise participants;5
! evaluate response, communications, and coordination activities of
emergency response organizations who are likely to be first on the
scene of an incident; and
! assess the utility of evaluative metrics, or help observers identify or
develop appropriate evaluative criteria.
Exercises might demonstrate that responders have the capacity to respond
effectively to an incident, or identify areas in which improvement is necessary.
Lessons learned from an exercise may provide insights to guide future planning for
securing the nation against terrorist attacks, disasters, and other emergencies. More
broadly, emergency preparedness exercise programs may provide insights about the
3 (...continued)
Corporation, 2005), available at [http://oversight.house.gov/documents/
20051209101110-81959.pdf]; Arlington County, Virginia, Arlington County After-Action
Report on the Response to the September 11 Terrorist Attack on the Pentagon, available at
[http://www.arlingtonva.us/departments/Fire/edu/about/FireEduAboutAfterReport.aspx];
and State of Colorado, Division of Emergency Management, After Action Report: Holiday
Blizzard 2006 (part 1), available at [http://www.dola.colorado.gov/dem/operations/aars/
aar_blizzard1.pdf].
4 For September 2008, the National Exercise Schedule System (NEXS) listed 56 exercises
and 75 conferences to prepare for future exercises to be carried out by federal, state,
territorial, local, and tribal entities. NEXS does not list private sector activities, and may
not include all preparedness exercises carried out by all levels of civilian government or the
military.
5 Under current civilian doctrine, discussed below, exercises are a means of testing
knowledge and training. Under military doctrine, exercises are a component of training.

CRS-3
efficacy of the government policies establishing responsibilities within agencies, and
whether those policies, organizational structures, and processes adequately ensure the
safety and security of public institutions, critical infrastructures, and American
citizens.
Current homeland emergency preparedness exercises, carried out through
authorities that created the National Exercise Program (NEP), attempt to build an
integrated, interagency federal, state, territorial, local, and private sector capability
to prevent terrorist attacks, and to rapidly and effectively respond to, and recover
from, any terrorist attack or major disaster that occurs. This report provides an
overview of emergency preparedness authorities and guidance; development and
management of the NEP; and current exercise planning, scheduling, and evaluation
processes. Additionally, it provides analysis of national preparedness policy issues
and exercise operations issues that Congress might consider. Legal authorities to
conduct national-level exercises and preparedness exercises in general are provided
in Appendix A. Since homeland preparedness activities are typically addressed by
planners and practitioners who use specialized terms and abbreviations, Appendix
B lists all acronyms used in this report together with their meaning.
Emergency Preparedness Authorities and Guidance
Current national emergency preparedness doctrine has developed over time,
pursuant to statute and various executive directives.6 Among the authorities
governing preparedness exercises are the following: The Post-Katrina Emergency
Management Reform Act of 20067; Executive Order (E.O.) 12656, Assignment of
Emergency Preparedness Responsibilities; and Homeland Security Presidential
Directive (HSPD) 8 on national preparedness.8
Post-Katrina Emergency Management Reform Act. The Post-Katrina
Emergency Management Reform Act requires the Administrator of the Federal
Emergency Management Agency (FEMA), “in coordination with the heads of
appropriate federal agencies, the National Council on Disability, and the National
Advisory Council” to “carry out a national exercise program to test and evaluate the
national preparedness goal, National Incident Management System, National
Response Plan (NRP),9 and other related plans and strategies.”10 The Post-Katrina
Emergency Management Reform Act national exercise program is mandated to be
6 Appendix A provides lists of specific mandates to conduct “national level preparedness
exercises,” and general mandates to conduct exercises.
7 Post-Katrina Emergency Management Reform Act of 2006, Oct. 4, 2006, P.L. 109-295,
120 Stat. 1394, et seq.
8 The text of HSPD 8 is available at [http://www.whitehouse.gov/news/releases/2003/12/
20031217-6.html].
9 The NRP was replaced by the National Response Framework (NRF) in January 2008.
10 P.L. 109-295, sec. 648(b), 6 U.S.C. 748.

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! as realistic as practicable, based on current risk assessments, credible
threats, vulnerabilities, and consequences;
! designed to stress the national preparedness system;
! designed to simulate the partial or complete incapacitation of a state,
territorial, local, or tribal government;
! carried out with a limited degree of notice to exercise players
regarding exercise timing and details;
! designed to provide for systematic evaluation of readiness; and
! designed to address the unique requirements of populations with
special needs.11
At least every two years the Administrator is required to carry out national
exercises “to test and evaluate the capability of federal, state, territorial, local, and
tribal governments to detect, disrupt, and prevent threatened or actual catastrophic
acts of terrorism, especially those involving weapons of mass destruction ... and to
test and evaluate the readiness of Federal, State, territorial, local, and tribal
governments to respond and recover in a coordinated and unified manner to
catastrophic incidents.”12
E.O. 12656. E.O. 12656 was issued November 18, 1988, by President Ronald
Reagan.13 It assigns national security emergency preparedness responsibilities to
federal departments and agencies; establishes a national security emergency exercise
program; and directs FEMA to coordinate the planning, conduct, and evaluation of
national security emergency exercises. E.O.12656 defines a national security
emergency as “any occurrence, including natural disaster, military attack,
technological emergency, or other emergency, that seriously degrades or seriously
threatens the national security of the United States.”14
HSPD-8. HSPD-8 requires the Secretary of Homeland Security, “in
coordination with other appropriate federal departments and agencies” to “establish
a national program and a multi-year planning system to conduct homeland security
preparedness-related exercises that reinforces identified training standards, provides
for evaluation of readiness, and supports the national preparedness goal.”15 The
11 The Administrator is also required to provide assistance to state, territorial, local, and
tribal governments with the design, implementation, and evaluation of exercises.
12 P.L. 109-295, sec. 648(b), 6 U.S.C. 748.
13 53 FR 47491; Nov. 23, 1988.
14 While the order defines “national security emergency” broadly, subsequent language
excludes “those natural disasters, technological emergencies, or other emergencies, the
alleviation of which is normally the responsibility of individuals, the private sector,
volunteer organizations, State and local governments, and Federal departments and agencies
unless such situations also constitute a national security emergency.”
15 The National Preparedness Goal, a forerunner of the National Preparedness Guidelines,
was released by DHS on an interim basis in 2005 to “guide federal departments and
agencies, state, territorial, local and tribal officials, the private sector, non-government
organizations and the public in determining how to most effectively and efficiently
(continued...)

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program is to be carried out in collaboration with state and local governments and
private sector entities. Federal departments and agencies that conduct national
homeland security preparedness-related exercises are required to “participate in a
collaborative, interagency process to designate such exercises on a consensus basis
and create a master exercise calendar.” The directive mandates that the Secretary of
Homeland Security “develop a multi-year national homeland security
preparedness-related exercise plan and submit the plan to the President through the
Homeland Security Council (HSC) for review and approval.”
Preparedness Guidance. Guidance materials and processes to assist the
implementation of national preparedness authorities are overseen at the federal level
by the Department of Homeland Security (DHS). These tools include the National
Response Framework (NRF), the National Incident Management System (NIMS),
and the National Preparedness Guidelines (NPG). NRF provides guidance for
conducting all-hazards emergency response. The framework describes specific
statutory and executive authorities, and what DHS describes as “best practices” for
managing incidents that range from the serious but purely local, to large-scale
terrorist attacks or catastrophic natural disasters. DHS says that NRF focuses
particularly on how the federal government is organized to support communities and
states in catastrophic incidents.16 According to DHS, NRF builds upon NIMS, an
incident management process that was reportedly developed so responders from
different jurisdictions and disciplines17 could work together to respond to natural
disasters and other emergencies, including acts of terrorism. NIMS utilizes “a
unified approach to incident management; standard command and management
structures; and emphasis on preparedness, mutual aid and resource management.”18
NPG provides a means to define all hazards preparedness; organize and synchronize
efforts to strengthen national preparedness; guide national investments in national
preparedness; incorporate lessons learned from past disasters into national
preparedness priorities; and establish readiness metrics and a system for assessing the
15 (...continued)
strengthen preparedness for terrorist attacks, major disasters, and other emergencies.”
Among the priorities identified by the goal were the implementation of the National Incident
Management System (NIMS), and the National Response Plan (NRP), a forerunner of the
NRF. See DHS, “Department of Homeland Security Releases Interim National
Preparedness Goal,” press release, Apr. 1, 2005, available at [http://www.dhs.gov/xnews/
releases/press_release_0648.shtm]; and Ibid., “HSPD-8 Overview,” available at
[http://www.ojp.usdoj.gov/odp/assessments/hspd8.htm]. The NPG superceded the interim
goal in 2007. For historical background, see CRS Report RL32803, The National
Preparedness System: Issues in the 109th Congress, by Keith Bea, available upon request.
16 U.S. Department of Homeland Security, National Response Framework, Jan. 2008, p. 1,
available at [http://www.fema.gov/pdf/emergency/nrf/nrf-core.pdf].
17 “Disciplines” in this context appears to mean different types of responders, including
police, fire, rescue and medical professionals, among others.
18 Federal Emergency Management Agency, National Integration Center (NIC) Incident
Management Systems Division home page, available at [http://www.fema.gov/emergency/
nims/index.shtm].

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Nation’s overall preparedness capability to respond to major events, especially those
involving acts of terrorism.19
Toward a “National” Exercise Program
While training and exercises are longstanding components of government
preparedness efforts,20 a program of national exercises that attempts to coordinate and
synchronize federal exercise activities, and incorporate state, territorial, local, and
tribal governments and the private sector, arguably has emerged only in the past
decade. A product of congressional and executive branch mandates, the program
appears to have been motivated in part by perceived shortcomings in previous
exercise efforts as well as deficiencies perceived in response to actual incidents.
19 See Department of Homeland Security, National Preparedness Guidelines, Sept. 2007,
available at [http://www.dhs.gov/xlibrary/assets/National_Preparedness_Guidelines.pdf],
p. 1.
20 The United States has used military exercises to provide training and capability
evaluations since the earliest days of the republic. A limited survey of civilian preparedness
efforts suggests that they resulted from a number of factors, including perceived threats, and
reactions to incidents that required emergency response. Following World War II (1939-
1946), preparedness evolved from a predominantly military concept into a joint military and
civilian effort to secure the country’s defenses and protect U.S. citizens. Activities to
prevent or mitigate the consequences of natural disasters, resource crises, economic
disruption, industrial or transportation accidents, and “certain forms of terrorist activity”
were developed in response to the perceived threats of the Cold War (1945-1991) between
the United States and the Soviet Union, and their respective allies. Disaster preparedness
involved the advance planning for coordination of public and private resources among
federal, state, territorial, local and private agencies and actors. Response capacity was based
on the provision of those resources in emergency circumstances “where existing resources
are unlikely to be sufficient to cope with the requirements imposed by disaster.” See U.S.
Congress, Joint Committee on Defense Production, Civil Preparedness Review: Part I,
Emergency Preparedness and Industrial Mobilization 95th Cong., 1st sess. (Washington:
GPO, 1977), pp. vii-10; quotes, pp 3, 4. Systematic attention to exercises was not identified
in the years prior to the 1970s. In 1979, FEMA established a National Security Emergency
Exercise program, featuring large-scale exercises involving many federal agencies.
Following a partial meltdown of a nuclear power plant at Three Mile Island, Pennsylvania,
FEMA was assigned responsibility for radiological incident preparedness; the agency
conducted hundreds of Radiological Emergency Preparedness (REP) exercises between
1979 and 2000, see Department of Justice (DOJ), and FEMA Press Release, “Justice
Department, Federal Emergency Management Agency to Conduct Domestic
Counterterrorism Exercises,” Apr. 27, 2000; and FEMA, “FEMA History,” available at
[http://www.fema.gov/about/history.shtm]. In the aftermath of the bombing of the Alfred
P Murrah federal building in Oklahoma City in 1995, Congress passed the Defense Against
Weapons of Mass Destruction Act of 1996 (P.L. 104-201, Title 14, 110 Stat. 2714, 50
U.S.C. 2301) to enhance domestic preparedness to respond to a terrorist attack. The act
required increased capability to respond to incidents involving nuclear, biological, chemical,
and radiological weapons of mass destruction (WMD), and required the Department of
Defense (DOD) to provide training and advice to civilian agencies at the federal, state and
local levels regarding response. The history of preparedness capacity building, training and
exercises arguably lay the foundation for FEMA and DHS efforts to prepare for potential
threats in more contemporary exercises, while the focus on interagency coordination and
cooperation at the federal level integrates military and civilian response capacity.

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Impetus for an exercise of national scope came in 1998. The Senate Committee
on Appropriations, noting that “few of the top officials of agencies have ever fully
participated” in ongoing preparedness exercises, directed in report language “that an
exercise be conducted in fiscal year 1999 with the participation of all key personnel
who would participate in the consequence management of ... an actual terrorist
event.”21 The result was the Top Officials (TOPOFF) exercise, the first of what was
to be a series of four full-scale simulation exercises.22 The series appears to have
been a de facto national program of exercises held biennially to “assess the nation’s
crisis and consequence management capacity under extraordinary conditions.”
TOPOFF exercises enabled high level federal officials and relevant participants to
“practice different courses of action, gain and maintain situational awareness, and
assemble appropriate resources.”23
TOPOFF exercise scenarios attempted to address several objectives, and
typically included several incidents occurring at multiple geographic locations. First,
they were designed to reveal potential emergency response vulnerabilities so that any
identified deficiencies could be addressed before an actual incident occurred.
Second, TOPOFFs were used to observe how national, state, and local levels of
government, as well as public and private organizations, might interact and
coordinate their emergency responses. Finally, it has been pointed out that TOPOFFs
might also have served other, more subtle objectives, including assuring the public
of the ability of the government to respond to the results of attacks, and to
communicate a message of deterrence to potential enemies.24
21 United States Senate, Departments of Commerce, Justice, and State, the Judiciary, and
Related Agencies Appropriation Bill, 1999, report to accompany S. 2260, 105th Cong., 2nd
sess., S.Rept. 105-235 (Washington: GPO, 1998), p.14.
22 TOPOFF 2000, May 17-24, 2000, simulated a biological attack in Colorado and New
Hampshire. TOPOFF 2, May 12-16, 2003, simulated radiological dispersal device (RDD)
and an outbreak of pneumonic plague. The exercise included pre-exercise intelligence play,
a cyber-attack, and credible terrorism threats against other locations. The venues in the
exercise included Washington and Illinois. TOPOFF 3, April 4-8, 2005, was a large-scale,
multipoint terrorist attack using biological and chemical weapons. The venues in the
exercise included Connecticut, New Jersey, the United Kingdom, and Canada. TOPOFF 4,
October 15-19, 2007, simulated the detonation of an RDD near a power plant. The venues
included Oregon, Arizona, and Guam.
23 DOJ and FEMA, “Justice Department, Federal Emergency Management Agency to
Conduct Domestic Counterterrorism Exercises,” Apr. 27, 2000.
24 Christina W. Erickson and Bethany A. Barratt, “Prudence or Panic? Preparedness
Exercises, Counterterror Mobilization, and Media Coverage - Dark Winter, TOPOFF 1 and
2,” Journal of Homeland Security and Emergency Management, vol. 1, issue 4 (2004), pp.
1-2.

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National Exercise Program25
As the Post-Katrina Emergency Management Reform Act was considered and
enacted, the White House was developing policy guidance to implement a national
exercise program. In briefings provided to various audiences in 2006 and 2007, the
Department of Defense (DOD) and DHS referred to HSC input and policy guidance
on national exercise planning. Principal documents in this development were
reported in those briefings to include a national exercise program charter and
implementation plan. According to a DOD presentation, more than 100 military
exercises26 were to be synchronized in FY2007 with exercises run under the auspices
of DHS.27
A White House memorandum entitled “National Exercise Program” and
identified by many observers as the “NEP charter,” outlines
a program for the coordination of all exercises conducted pursuant to
strategies or plans prepared pursuant to Presidential direction. The program
will include processes to examine and improve the Nation’s ability to
prevent, prepare for, respond to and recover from terrorist attacks, major
disasters and other emergencies.28
The charter requires
officers of the United States Government (USG) to: (a) exercise their
responsibilities under the National Response Plan and other strategies, as
appropriate; (b) examine emerging policy issues through the conduct of
exercises in a comprehensive manner on a routine basis; (c) incorporate
current threat and vulnerability assessments into the exercise objectives and
planning effort; (d) develop a corrective action process to ensure lessons from
exercises are either sustained or improved as appropriate; and (e) achieve
national unity among appropriate Federal, State, local, private sector, and
appropriate partner nation entities.29
25 This section and related sections that follow are based on Homeland Security Council,
National Exercise Program Implementation Plan, June 20, 2008 (hereafter, NEP
implementation plan), and other sources as indicated.
26 DOD-based exercises include components of the Chairman’s (of the Joint Chiefs of Staff)
Exercise Program (CEP) and the Joint Exercise Program (JEP).
27 See Department of Homeland Security, “National Exercise Program,” presentation at the
DOD Worldwide Joint Training and Scheduling Conference 2007-1 (WJTSC 07-1), Mar.
8, 2007; and Department of Defense, Joint Staff, “Exercise Synchronization Working
Group,” presentation at the DOD Worldwide Joint Training and Scheduling Conference
2006-2 (WJTSC 06-1), Oct. 2, 2006. Both presentations are available from the authors upon
request.
28 White House, “National Exercise Program” (hereafter NEP charter) undated, p.3,
available from the authors upon request.
29 Ibid.

CRS-9
Citing paragraph 18 of HSPD 8 and section 648 of the Post-Katrina Emergency
Management Reform Act, the National Exercise Program Implementation Plan
(NEP implementation plan), issued in June 2008, formally establishes the NEP
“under the leadership of the Secretary of Homeland Security.”30 According to the
plan, the “principal focus of the NEP is to coordinate, design and conduct a program
of exercises designed for the participation of Federal department and agency
principals and other key officials....” The NEP implementation plan states that the
“DHS-led program required pursuant to” the Post-Katrina Emergency Management
Reform Act and HSPD-8 “has been renamed the Homeland Security Exercise and
Evaluation Program (HSEEP),” [hereafter HSEEP exercise program]31 with the NEP
serving as “the overarching exercise program directed at principals” of federal
agencies and other officials “...to ensure the USG has a single, comprehensive
exercise program.”32 The NEP is used to examine and evaluate national policy issues
and guidance, including the NPG, NIMS, NRF, and other related plans and strategies
to provide domestic incident management, “either for terrorism or non-terrorist
catastrophic events.” According to the implementation plan, the NEP incorporates
exercise planning, design and evaluation methods and various federal department and
agency exercise programs:
The NEP incorporates HSEEP [exercise program] as well as other department
and agency exercise programs, but gives a collective voice to the interagency
exercise community in making the best use of this well-resourced DHS
program in order to satisfy USG [U.S. Government]-wide requirements
including providing assistance to state, local and tribal governments with the
design implementation and evaluation of exercises. All departments,
agencies, or offices responsible for coordinating exercises related to
Presidentially-directed strategies and plans shall utilize the NEP as the means
of coordination and conduct of such exercises. All departments, agencies, or
offices shall plan and budget appropriately to support the exercise planning
cycle and exercise participation.33
NEP Management and Coordination. Within the White House, the NEP
is managed through an interagency process overseen by the Homeland Security
Council and the National Security Council (NSC). Day-to-day coordination of the
program is carried out by the White House Domestic Readiness Group 34 exercise and
30 NEP implementation plan, p. 1.
31 It appears that the HSEEP exercise program, incorporating the Post-Katrina Emergency
Management Reform Act and HSPD-8 exercise programs as described in the NEP
implementation plan, is different from the longstanding HSEEP exercise design,
development, conduct, evaluation, and improvement planning methodology (the HSEEP
method) maintained by FEMA, and discussed below.
32 NEP implementation plan, p. 1.
33 NEP implementation plan, p. 3.
34 The status and membership of the Domestic Readiness Group could not be determined.
In the NRF, it is described as “an interagency body convened on a regular basis to develop
and coordinate preparedness, response, and incident management policy. This group
(continued...)

CRS-10
evaluation policy coordinating subcommittee (DRG E&E Sub-PCC). A steering
committee is responsible for staff-level coordination of the NEP. The steering
committee also frames issues and recommendations for the DRG E&E Sub-PCC on
exercise themes, goals, objectives, scheduling and corrective actions. The steering
committee is chaired and facilitated by FEMA’s National Exercise Division,35 with
staff support provided by agencies that sit on the steering committee.36 HSC, NSC,
and the Office of Management and Budget (OMB) participate in the steering
committee in a non-voting, oversight capacity.
NEP Requirements for Federal Executive Agencies. The strategic
objectives of the NEP charter are to
1) Exercise senior USG officials; 2) Examine and evaluate emerging national
level policy issues; 3) Practice efforts to prevent, prepare for, respond to and
recover from terrorist attacks, major disasters, and other emergencies in an
integrated fashion from the federal level down to state, local, and private
sector level; and 4) Identify and correct national-level issues, while avoiding
repetition of mistakes.37
Generally, the NEP implementation plan requires all federal executive agencies
to
! provide resource and budget support for the planning and conduct of
certain NEP exercises unless specifically relieved of this
requirement by both the Assistant to the President for National
Security Affairs (APNSA) and the Assistant to the President for
Homeland Security and Counterterrorism (APHS/CT);
! provide principal- or deputy-level support to national and principal
level exercises;
34 (...continued)
evaluates various policy issues of interagency importance regarding domestic preparedness
and incident management and makes recommendations to senior levels of the policymaking
structure for decision. During an incident, the Domestic Readiness Group may be convened
by DHS to evaluate relevant interagency policy issues regarding response and develop
recommendations as may be required.” No specific membership was identified. See DHS,
National Response Framework, p. 55.
35 The National Exercise Division is a part of FEMA’s National Preparedness Directorate.
Department of Homeland Security/FEMA, National Preparedness Directorate, briefing for
the Committee on Homeland Security and Governmental Affairs, June 12, 2008 (hereafter
DHS/FEMA briefing).
36 Members of the steering committee include DHS Office of Operations Coordination;
DHS/FEMA Disaster Operations; DOD, Office of the Secretary of Defense; DOD, Joint
Staff; Department of Justice; Federal Bureau of Investigation; Department of State; Office
of the Director of National Intelligence, Department of Energy; Department of
Transportation; and the Department of Health and Human Services. Up to two additional
members from the DRG E&E Sub-PCC, currently the Department of Treasury and the
Environmental Protection Agency, may serve one-year terms, on a rotating basis.
37 NEP charter, p.3.

CRS-11
! participate in the planning and conduct of certain DHS- led NEP
national and regional simulation requirements;
! designate an exercise and evaluation point of contact (POC) for
coordination with the NEP ESC;
! submit annually to the NEP ESC a prioritized list of exercise
objectives and capabilities they wish to exercise and evaluate;
! maintain a corrective action program (CAP) that can generate input
for, and track assignments from, an interagency NEP corrective
action program, described below;
! report their sponsored exercise activities to a national exercise
schedule;
! have an exercise participation decision process that accords priority
to certain NEP events; and
! develop and report on output, outcome and efficiency measures to
guide evaluation of exercise and related training programs as they
relate to the NEP. The results of the report shall be submitted to
OMB concurrently with the agencies’ annual budget submissions.
The plan also assigns specific responsibilities to a number of entities and
officials.38
NEP Corrective Action Program. The NEP implementation plan requires
the establishment of a corrective action program (NEP CAP), administered by DHS
in support of HSC and NSC, to provide a government-wide process for identifying,
assigning, and tracking remediation of interagency issues identified through
exercises.
NEP Exercises
The NEP implementation plan describes three broad categories of exercises —
national level exercise (NLE), principal level exercises (PLE), and NEP classified
exercises.
National Level Exercise. The NEP implementation plan describes an NLE
as the single, annual operations-based exercise focused on White House directed,
government-wide strategy and policy-related issues. An NLE requires the
participation of all appropriate department and agency principals or their deputies,
other key officials,39 and all related staff, operations and facilities at national, regional
38 Entities and officials assigned specific management, oversight, or programmatic
responsibilities in the NEP implementation plan include APHS/CT; APNSA; DOD; DHS;
Office of Director of National Intelligence; Department of State; DRG E&E Sub-PCC; ESC;
OMB; and Tier I or Tier II exercise steering committees tasked with developing and
managing specific exercises.
39 According to the NEP implementation plan, other key officials include the Chief of Staff
to the President, APNSA, APHS/CT, the Assistant to the President for Domestic Policy, the
Chairman of the Joint Chiefs of Staff (CJCS), and the Director of National Intelligence
(DNI).

CRS-12
and local levels.40 NLEs examine the preparation of the government and its officers
and other officials to prevent, respond to, or recover from threatened or actual
terrorist attacks, particularly those involving weapons of mass destruction (WMD),
major disasters, and other emergencies. NLEs address strategic- and policy- level
objectives intended to challenge the national preparedness of the United States.
Federal executive agency exercise planning activities that support national priorities
and objectives, specified in various Presidential directives, may be incorporated into
NLEs. An NLE may involve all levels of federal, state, and local authorities and may
involve critical private-sector entities, or international partners, as appropriate.
NLE scenarios are based on the response requirements of one of 15 National
Planning Scenarios (NPS),41 and one of the components of the NPG. The NPS are
high-consequence threat scenarios of both potential terrorist attacks and natural
disasters that could necessitate emergency response. DHS argues that they are
designed to focus contingency planning for homeland security preparedness work at
all levels of government and the private sector.42
Principal Level Exercise. PLEs address emerging threats and issues
requiring senior-level attention, and establish and clarify roles and responsibilities,
as well as strategy and policy, for government-wide activities. The NEP includes
four discussion-based PLEs per year, and requires the participation of all appropriate
department and agency principals or their deputies. One PLE serves as a preparatory
event for the annual NLE. The topic for one of the PLEs is not decided until the year
it is conducted. DHS conducts PLEs in consultation with HSC and NSC staffs.
DOD provides technical assistance, while “all other departments and agencies”
provide “appropriate assistance.”
NEP Classified Exercises. Some aspects of federal executive branch efforts
to prevent and respond to threatened or actual terrorist attacks, major disasters, and
other emergencies are national security classified, restricted to select executive
agencies, and must be exercised and evaluated within the context of ongoing exercise
prevention or response operations. Classified exercise activities are incorporated into
some NEP exercises. The NEP implementation plan notes that classified exercises
“should be a logical component of the exercise scenario and aligned with exercise
objectives.”
40 The NEP implementation plan indicates that an NLE may be a functional exercise (FE),
a full-scale exercise (FSE), or a combination of both, but does not define FE or FSE.
Exercise types are identified in various DHS/FEMA guidelines. See “Exercise Development
and Implementation Guidance,” below.
41 The NPS include aerosol anthrax; blister agent; chlorine tank explosion; cyber attack;
food contamination; foreign animal disease; improvised explosive device (IED); improvised
nuclear device (IND); major earthquake; major hurricane; nerve agent; pandemic influenza
(PI); plague; radiological dispersal device (RDD); and toxic industrial chemicals. See DHS,
National Preparedness Guidelines, p. 31, available at [http://www.dhs.gov/xlibrary/
assets/National_Preparedness_Guidelines.pdf].
42 DHS/ FEMA briefing, June 12, 2008.

CRS-13
NEP Exercise Categories. The NEP categorizes exercise activities into four
tiers reflecting the priority for national and regional federal interagency participation.
Exercises are assigned to tiers according to a consensus interagency judgment
expressed in the DRG E&E Sub-PCC of how closely they align to government-wide
strategic and policy priorities. The four tiers, numbered I through IV, are as follows:
Tier I. Tier I exercises include an annual NLE and four quarterly PLEs. The
exercises are centered on White House directed, government-wide strategy and
policy-related issues; federal executive agency participation is required. FEMA’s
National Exercise Division is the lead planning agent for the NEP Tier I exercises,
unless otherwise stipulated by the Domestic Readiness Group.
Tier II. Tier II exercises include federal executive agency exercises that focus
on government strategy, policy and procedural issues meriting priority for national
and regional federal interagency participation. Tier II exercises may be carried out
through the National Simulation Center, or as determined by a sponsoring agency’s
leadership. A federal executive agency that sponsors a Tier II exercise is responsible
for leading the coordination, planning, conduct, and evaluation of the exercise.
FEMA’s National Exercise Division is responsible for coordinating federal, national
interagency simulation of exercises. This may be accomplished through the National
Simulation Center, or by coordinating federal regional simulation as required to
support an exercise. The DRG E&E Sub-PCC shall recommend no more than three
Tier II exercises each year for federal, national, and regional interagency
participation.
Tier III. Tier III exercises include other federal exercises focused on regional
plans, policies and procedures. The exercises may focus on operational, tactical, or
organization-specific objectives that do not require broad interagency
headquarters-level involvement to achieve their stated exercise or training objectives.
Participation in Tier III exercises by national level assets is at the discretion of each
federal executive agency. Tier II exercises take precedence over Tier III exercises in
the event of resource conflicts.
Tier IV. Tier IV exercises are exercises in which state, territorial, local, or tribal
governments and private sector entities are the primary audience or subject of
evaluation.
Exercise Scheduling. The NEP implementation plan requires the
development and annual revision of a five-year schedule of exercises by the Secretary
of Homeland Security, in coordination with the principals of other relevant
departments and agencies.43 As part of an annual scheduling process, federal
executive agencies may nominate an exercise for consideration as a Tier II exercise.
43 Some presentations on the NEP have suggested that changes to an exercise theme or
scenario should not be attempted within two years of an exercise, in order to allow exercise
planners the opportunity to design the exercise. Since the first five-year NEP schedule
commenced at the beginning of FY2007 (October, 2006), however, it has yet to be
determined whether efforts to maintain the exercise schedule and NLE themes have been
established or are being enforced.

CRS-14
The NEP implementation plan appears to be unclear whether participating agencies
are required to fit their entire exercise programs into the NEP framework.44 When
they participate in NLEs, however, agencies are expected to shape their participation
to fit the themes and schedules of NLE scenarios.45 In a preliminary example of this
approach, during NLE 1-08, a Tier I exercise, TOPOFF 4 ran simultaneously with
DOD- and Department of Health and Human Services (HHS)- based exercises.46 In
NLE 2-08, a tier II exercise, two FEMA exercises, Eagle Horizon 08, designed to
exercise the continuity of operations (COOP) capabilities of federal agencies in the
National Capital Region (NCR), and Hurricane Prep 08, designed to test FEMA
response to a hurricane, exercised under the same scenario. Both exercises
incorporated some of the simulated intelligence materials established for three DOD
conducted exercises held during NLE 2-08: Positive Response 08-2; Ardent Sentry
08; and Ultimate Caduceus 08.
Emergency management staff in DHS and DOD indicate that exercise activities
carried out during FY2007 and FY2008 reflected a period of transition to the NEP.
Scheduled and planned prior to the implementation of the National Exercise
Schedule (NEXS) and NLE processes, the exercises were somewhat less unified in
terms of exercise scenarios and objectives than those anticipated by the NEP. The
individual exercise components of NLE 2-08 appear to have been carried out
essentially independently by DHS and DOD components, and the extent of
interactions of players from different agencies is unclear. On the other hand, some
interagency coordination occurred at higher, more strategic levels. During the NLE
2-08 planning process, DOD and DHS held joint planning conferences. Further,
DOD provided some logistical support to the DHS Eagle Horizon continuity
exercise, which based its exercise control cell and some evaluation components at
DOD’s Joint Warfighting Center (JWFC).47 Both agencies anticipate future NLEs
will be carried out according to timing specified in the NEP implementation plan,
based on common exercise scenarios and coordinated response activities.48
44 At various points, the plan appears to provide ambiguous, potentially confusing guidance:
“The NEP is intended to provide a framework for prioritizing and focusing Federal exercise
activities, without replacing any individual department or agency exercise program”(NEP
implementation plan, p. 2); and “All departments and agencies shall have an have an
exercise participation decision process that accords priority to NEP Tier I and Tier II
events.” (Ibid., p. 17). See “NEP and Existing Agency Exercise Activities,” below.
45 Department of Homeland Security, “National Exercise Program,” Mar. 8, 2007.
46 DHS said that during TOPOFF 4, “the U.S. Department of Health and Human Services
(HHS) mobilized around emerging public health issues related to a radiological emergency,
and the U.S. Department of Defense (DOD) ran concurrent exercises to address global terror
threats.” See “The TOPOFF 4 Full-Scale Exercise,” available at [http://www.dhs.gov/
xprepresp/training/gc_1179430526487.shtm]. The TOPOFF exercise series was terminated
following TOPOFF 4. Future exercises that meet the requirements of the TOPOFF program
will run as NLEs. DHS/FEMA briefing, June 12, 2008.
47 See FEMA, “National Level Exercise (NLE) 2-08 Eagle Horizon 2008 (EH 08)
Participant Briefing,” May 7, 2008. Information on the JWFC is available at
[http://www.jfcom.mil/about/abt_j7.htm].
48 DHS/FEMA briefing, June 12, 2008; Department of Defense, Office of Secretary of
(continued...)

CRS-15
DOD Participation in the National Exercise Program
Historically, military exercises have been designed, planned, executed, and
evaluated primarily by the individual military services; but in recent decades there
has been greater emphasis on joint exercises, which involve two or more services.
DOD participation in the NEP will normally occur as a joint military exercise linked
to an NEP event. Doctrine and guidance for the conduct of joint military exercises
is contained in several key documents. Of particular importance are Chairman of the
Joint Chiefs of Staff Instruction (CJCSI) 3500.01D, Joint Training Policy, which
establishes policy for planning and conducting joint training (which includes
exercises), and Chairman of the Joint Chiefs of Staff Manual (CJCSM) 3500.03B
Joint Training Manual for the Armed Forces of the United States, which provides
guidance to Combatant Commanders on implementing policies for planning and
conducting joint training. While the military’s joint doctrine differs somewhat from
the HSEEP method, there are deep similarities between them because the latter was
heavily influenced by the former.
Role of DOD in NEP Events. NEP events are intended to focus “principally
on domestic incident management, either for terrorism or non-terrorist catastrophic
events.”49 In the event of such an incident, there are two principal areas in which
DOD would play a significant role in the overall response: homeland defense
operations and civil support operations. DOD defines homeland defense as “The
protection of United States sovereignty, territory, domestic population, and critical
defense infrastructure against external threats and aggression or other threats as
directed by the President.”50 Within the context of the NEP, this homeland defense
capability might be exercised through scenarios that include a pending terrorist attack
(for example, interdicting ships containing radiological material before they arrived
at an American port, or intercepting an explosives-laden aircraft). DOD defines civil
support as “Department of Defense support to US civil authorities for domestic
emergencies, and for designated law enforcement and other activities.”51 Civil
support missions include assisting civil authorities in their response to manmade and
natural disasters, supporting public health, and maintaining civil order. Within the
48 (...continued)
Defense (OSD), for staff of the Congressional Research Service (CRS), July 23, 2008
(hereafter OSD briefing); Department of Defense, National Guard Bureau (NGB) for CRS
staff, August 5, 2008 (hereafter NGB briefing).
49 NEP implementation plan, p. 1.
50 Joint Publication 1-02, Department of Defense Dictionary of Military and Associated
Terms, as amended through August 26, 2008, available at [http://www.dtic.mil/
doctrine/jel/new_pubs/jp1_02.pdf]. The definition of homeland defense is distinct from the
definition of homeland security, which is defined as “a concerted national effort to prevent
terrorist attacks within the United States; reduce America’s vulnerability to terrorism, major
disasters, and other emergencies; and minimize the damage and recover from attacks, major
disasters, and other emergencies that occur.” See also JP 3-27, Homeland Defense, July 12,
2007, available at [http://www.dtic.mil/doctrine/jel/new_pubs/jp3_27.pdf].
51 Joint Publication 1-02, Department of Defense Dictionary of Military and Associated
Terms, as amended through August 26, 2008, available at [http://www.dtic.mil/doctrine/
jel/new_pubs/jp1_02.pdf].

CRS-16
context of the NEP, DOD’s civil support capability might be exercised through
scenarios that include the national response to a completed terrorist attack or a
catastrophic disaster (for example, assisting with medical evacuation of injured
people, or providing personnel and equipment to conduct search and rescue
missions).
At the policy level, DOD is directly involved in the ongoing development,
coordination, and execution of the NEP.52 It has representatives from both the Office
of the Secretary of Defense (OSD) and the Joint Staff (J7)53 on the DRG E&E Sub-
PCC, which makes recommendations on exercise priorities, schedules, and corrective
action. DOD also has OSD and J7 representatives on the NEP ESC, which
coordinates the NEP at the staff level. Twice a year, DOD conducts a Worldwide
Joint Training and Scheduling Conference (WJTSC) which coordinates exercise
plans and schedules from the Combatant Commands. The finalized results of these
conferences are submitted in December of each year to DHS for inclusion in the
National Exercise Schedule. In this manner, the timing of many large-scale DOD
exercises has been synchronized with NEP generally, and particularly the NLEs.
At the operational level, DOD participates in NEP events primarily through U.S.
Northern Command (USNORTHCOM) and the National Guard. USNORTHCOM
is the DOD Combatant Command with primary responsibility for homeland defense
and civil support operations in the United States (not including Hawaii, Puerto Rico,
and U.S. territories).54 For example, during NLE 1-08, USNORTHCOM and the
North American Aerospace Defense Command (NORAD)55 conducted Vigilant
Shield 08 to test the ability of the military to conduct civil support operations in
response to a scenario in which the main event, TOPOFF 4, was the explosion of
52 Much of the information in this paragraph was provided by the Joint Staff Legislative
Affairs office by e-mail to CRS on May 28, 2008.
53 J7 is the directorate responsible to the Joint Chiefs of Staff (JCS) for Operational Plans
and Joint Force Development, and has responsibility for exercise development and
evaluation.
54 NORTHCOM’s mission is to “anticipate and conduct Homeland Defense and Civil
Support operations within the assigned area of responsibility to defend, protect, and secure
the United States and its interests. USNORTHCOM’s area of responsibility includes air,
land and sea approaches and encompasses the continental United States, Alaska, Canada,
Mexico and the surrounding water out to approximately 500 nautical miles. It also includes
the Gulf of Mexico and the Straits of Florida. The defense of Hawaii and U.S. territories and
possessions in the Pacific is the responsibility of U.S. Pacific Command. The defense of
Puerto Rico and the U.S. Virgin Islands is the responsibility of U.S. Southern Command.
The commander of USNORTHCOM is responsible for theater security cooperation with
C a n a d a a n d M e x i c o . ” S e e “ A b o u t N O R T H C O M , ” a v a i l a b l e a t
[http://www.northcom.mil/About/index.html]. See also CRS Report RL34342, Homeland
Security: Roles and Missions for United States Northern Command, by William Knight.
55 NORAD is a bi-national U.S. and Canadian organization charged with air and maritime
warning and airspace control. USNORTHCOM and NORAD are both commanded by the
same individual; however, while NORAD and USNORTHCOM are collocated, they remain
separate, but complementary entities. NORAD was established by treaty, and in May 2006,
NORAD’s maritime warning mission was added.

CRS-17
radiological dispersion devices in Guam, Oregon, and Arizona. As part of NLE 2-08,
Ardent Sentry 08 tested DOD’s ability to conduct civil support operations in response
to terrorist attacks in the Pacific Northwest and a hurricane striking the mid-Atlantic
states.56
Other combatant commands may provide support to USNORTHCOM during
an NEP event. For example, during NLE 2-08, U.S. Transportation Command
(USTRANSCOM) supported Ardent Sentry by conducting exercise Ultimate
Caduceus. This exercise was designed to demonstrate and assess USTRANSCOM’s
Joint Task Force - Port Opening57 capability to respond to mass casualty scenarios
through aerial evacuation of patients.58 Ultimate Caduceus required USTRANSCOM
to coordinate the aeromedical evacuation of patients, train Air Force aeromedical
crews on the use of Civil Reserve Air Fleet (CRAF)59 aircraft, and validate patient
load configurations using CRAF aircraft.60
National Guard Participation. The National Guard also plays a prominent
role in NEP events. The National Guard Bureau (NGB) is a joint activity of the
Department of Defense and one of its functions is to assist the Secretary of Defense
in coordinating the use of National Guard personnel with USNORTHCOM and
certain other entities.61 However, while NGB is a DOD entity, the National Guard
itself is both a federal and a state organization.62 When the National Guard
56 Fact Sheet, USNORTHCOM Portion of NLE 2-08, Mar. 7, 2008, provided to CRS by
USNORTHCOM Public Affairs Office.
57 Joint Task Force — Port Opening is a command and control expeditionary capability
designed to rapidly establish an initial theater port of debarkation, aiding in deployment and
distribution operations supporting military contingencies, humanitarian aid and disaster
relief operations.
58 U.S. Transportation Command Press Release, “Command Plays Major Role in National
Exercise,” April 30, 2008, on-line at [http://www.transcom.mil/pa/
body.cfm?relnumber=080430-1].
59 Under the CRAF, commercial air carriers voluntarily commit airliners to support DOD
airlift requirements in emergencies when the need for airlift exceeds the capability of the
military aircraft fleet. In exchange, commercial air carriers receive access to peacetime
airlift business from DOD. For more information, see CRS Report RL33692, Civil Reserve
Air Fleet, by William Knight and Christopher Bolkcom.
60 Fact Sheet, Ultimate Caduceus, provided to CRS by USTRANSCOM Public Affairs
Office.
61 Note that the relationship of the National Guard Bureau to the various state and territorial
National Guard organizations is one of coordination, not of command.
62 The National Guard is usually both a state and a federal organization. The National Guard
of the United States is made up of 54 separate National Guard organizations: one for each
state, and one for Puerto Rico, Guam, the U.S. Virgin Islands, and the District of Columbia.
While the District of Columbia National Guard is an exclusively federal organization and
operates under federal control at all times, the other 53 National Guards operate as state or
territorial organizations most of the time. In this capacity, each of these 53 organizations is
identified by its state or territorial name (e.g. the California National Guard or the Puerto
Rico National Guard), and is controlled by its respective governor.

CRS-18
participates in NEP events, it does so in its capacity as a state militia under the
control of a governor. This is consistent with the manner in which the National
Guard would most likely be utilized in responding to an actual domestic incident.
Although National Guard personnel can be federalized to respond to certain domestic
incidents, it normally remains in a state-controlled status during such events. State
control has some key advantages. For example, National Guard personnel under state
control are integrated into the command and control structure that directs state and
local response efforts, and they may perform law enforcement duties as they are not
affected by the Posse Comitatus Act.63 The National Guard of a state typically makes
up a significant portion of a state’s response force during a NEP event. During NLE
2-08, the Washington National Guard conducted civil support operations in their
home state in response to a simulated terrorist attack, a tanker truck explosion, and
the accidental release of a hazardous chemical. They remained under the control of
their governor throughout the exercise.
Exercise Development and
Implementation Guidance
Guidance related to civilian NEP and other exercises is based in part on
FEMA’s Homeland Security Exercise and Evaluation Program (HSEEP method).64
Based on DOD exercise doctrine and modified for use in a civilian environment,65
the HSEEP method provides a “a capabilities and performance-based exercise
program that provides a standardized methodology and terminology for exercise
design, development, conduct, evaluation, and improvement planning.66 For federal
departments and agencies, the NEP implementation plan identifies the HSEEP
method as one of several “authorities and references,”and as “the doctrinal
63 The Posse Comitatus Act (18 U.S.C. 1385), along with other related laws and
administrative provisions, prohibits the use of the military to execute civilian laws unless
expressly authorized by the Constitution or an act of Congress. When acting in its capacity
as the organized militia of a state, the National Guard is not part of the federal military and
thus is not covered by the Posse Comitatus Act. As such, the National Guard can be used
by state authorities to enforce the law. Only when it is called into federal service does the
National Guard become subject to the act.
64 “HSEEP” is used as an acronym in two contexts related to the NEP. In one instance,
identified as the “HSEEP exercise program” in this report, it refers to the combined Post-
Katrina Emergency Management Reform Act and HSPD-8 exercise programs as described
in the NEP implementation plan, as discussed above. Another instance, discussed in this
section, and identified in this report as the “HSEEP method,” refers to FEMA’s
longstanding exercise design implementation and evaluation program. On its website,
FEMA identifies the HSEEP method as “a capabilities and performance-based exercise
program that provides a standardized methodology and terminology for exercise design,
development, conduct, evaluation, and improvement planning” and “constitutes a national
standard for all exercises,” available at [https://hseep.dhs.gov/pages/1001_HSEEP7.aspx].
65 OSD briefing July 23, 2008; and NGB briefing August 5, 2008.
66 See the HSEEP method website at [https://hseep.dhs.gov/pages/1001_HSEEP7.aspx].

CRS-19
foundation for all tiers of NEP exercise activity.”67 Guidance for implementing
HSEEP has been disseminated widely to federal executive departments and agencies.
Nevertheless, no explicit statutory or executive authority that compels federal
agencies to use the HSEEP method was identified. If exercises conducted by state,
territorial, local, or tribal government entities are paid for with funds obtained
through the DHS Homeland Security Grant Program (HSGP), they “must be
managed and executed in accordance with” the HSEEP method.68 DHS/FEMA staff
assert that the HSEEP method is well accepted by federal executive departments and
agencies, as well as state, territorial, local and tribal governments, and there is some
evidence to support that assertion.69
In practice, a common framework for exercise design, development, and
conduct is arguably a necessary element, particularly for managing NEP-sanctioned
interagency exercises to test national level response strategies and leadership of
executive branch departments and agencies. Without such a framework, it is unclear
how the NEP CAP could function as a means to identify and track interagency issues
identified through the NEP. At the same time, the NEP implementation plan does
not clearly distinguish how the HSEEP method might be used to address differences
between strategic, government-wide, or interagency issues, and operational or tactical
issues that may be of concern only to one department or agency. Where the former
might be addressed through the NEP CAP interagency process, the latter may be
subject to extant exercise methods and processes that are internal to the relevant
agency. This potential concern is most prominent regarding Tier 3 and 4 intra-agency
exercises, since the NEP does not explicitly prohibit the use of internal exercise
methodology or doctrine at those exercise levels. Interagency and internal, agency-
specific issues could also arise in the context of Tier 1 and 2 exercises.
67 NEP implementation plan, pp. 2, 4.
68 See DHS, Fiscal Year 2008 Homeland Security Grant Program Guidance and Application
Kit, Feb. 2008, available at [http://www.fema.gov/pdf/government/grant/hsgp/
fy08_hsgp_guide.pdf].
69 In discussions with CRS, Kelly Jo Craigmiles, Exercise Training Officer, Oregon
Emergency Management, August 14, 2008 (hereafter Oregon OEM); Carmen Merlo,
Director, Portland, Oregon Office of Emergency Management, August 18, 2008 (hereafter,
Portland OEM); and Department of Justice, Bureau of Alcohol Tobacco, Firearms and
Explosives (ATF) staff, August 15, 2008 (hereafter ATF briefing) all indicated that their
agencies used the HSEEP method.

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The NEP implementation plan applies the HSEEP method’s framework of seven
exercise types.70 Four of the seven types, which include, seminars,71 workshops,72
tabletop exercises (TTX),73 and games,74 are discussion-based exercises.
Discussion-based exercises typically focus on strategic, policy-oriented issues, or are
used to highlight existing plans, policies, and procedures. Operations-based
exercises, which include drills,75 functional exercises (FE),76 and full-scale exercises
(FSE),77 are used to validate the plans, policies, agreements and procedures
developed in discussion-based exercises. Operations-based exercises are
characterized by actual reaction to simulated intelligence; response to emergency
70 NEP implementation plan, pp. 14-15.
71 The HSEEP method guidance describes a seminar-based exercise as “an informal
discussion, designed to orient participants to new or updated plans, policies, or procedures.”
See DHS, “Homeland Security Exercise and Evaluation Program: Terminology,
Methodology, and compliance Guidelines,” available at [https://hseep.dhs.gov/support/
HSEEP_101.pdf]. Also see, generally, Environmental Protection Agency (EPA),
“Exercises,” available at [http://www.epa.gov/radiation/rert/exercises.html].
72 A workshop is similar to a seminar, “but is employed to build specific products, such as
a draft plan or policy.” Ibid.
73 A TTX “involves key personnel discussing simulated scenarios in an informal setting.”
Ibid. TTX participants may test an emergency response plan and its standard operating
procedures by informally discussing, or “walking through,” a hypothetical emergency. A
TTX may also be used as a followup to an exercise. Following the Oct. 2007 TOPOFF 4
full scale exercise (FSE), a two-day TTX was held. The exercise brought “together leaders
from government, private sector, and nongovernmental organizations (NGOs) to discuss key
technical, operational, and policy challenges surrounding recovery from the detonation” of
radiological dispersion device (RDD), and long-term recovery issues from 50 days after a
detonation. See Interagency Coordinating Council on Emergency Preparedness and
Individuals with Disabilities, “DHS Participation in TOPOFF 4 Continues,” Nov. 2007,
available at [http://www.disabilitypreparedness.gov/bulletins/nov_07.htm].
74 Games are simulations “of operations that often involves two or more teams, using rules,
data, and procedure designed to depict an actual or assumed real-life situation.” Ibid.
75 The HSEEP method guidance describes a drill as “a coordinated, supervised activity
usually employed to test a single, specific operation or function within a single entity....”
Ibid. This could include emergency medical services conducting a field decontamination.
76 Functional exercises, examine “the coordination, command, and control between various
multi-agency coordination centers,” including emergency operation centers (EOC), joint
field offices (JFO), and similar facilities. An FE does not involve the deployment of
resources to the field to respond to a simulated incident in real time. Ibid. An FE may also
be referred to as a “command post exercise”(CPX). A DHS press release described the
TOPOFF 4 CPX, for example, as “real-time, functional assessments of communications,
planning, and decision-making capabilities in a time of crisis” in which “limited numbers
of emergency response personnel were deployed into the field.” Department of Homeland
Security, “U.S. Department of Homeland Security Announces Completion of TOPOFF 4
Command Post Exercise to Address Counterterrorism Preparedness and Response
Capabilities,” press release, June 22. 2006, available at [http://www.dhs.gov/xnews/
releases/press_release_0932.shtm].
77 A full-scale exercise is a multi-agency, multi-jurisdictional, multi-discipline exercise
involving functional field response.

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conditions; mobilization of apparatus, resources and/or networks; and commitment
of personnel, usually over an extend period of time.
Structurally, the HSEEP method is divided into five volumes. Volume I, HSEEP
Overview and Exercise Program Management,78 provides guidance for building and
maintaining an effective exercise program, and summarizes the planning and
evaluation process. Subsequent volumes describe those processes in detail. Volume
II, Exercise Planning and Conduct,79 provides an outline for a standardized exercise
foundation,80 and design, development, and conduct processes adaptable to any type
of exercise, and is discussed below. Volume III, Exercise Evaluation and
Improvement Planning,81 offers a method for evaluating and documenting exercises
and implementing an improvement plan, and is also discussed below. Volume IV,
Sample Exercise Documents and Formats,82 provides sample exercise materials.
Volume I serves as an introduction to the HSEEP method; Volume IV exists as a
document database to authorized users. Consequently, Volumes II and II , which
provide exercise planning and conduct, and exercise evaluation and improvement
planning, respectively, are discussed below.
Exercise Planning: The HSEEP Method, Volume II. Volume II of the
HSEEP method, Exercise Planning and Conduct,83 assists users in constructing an
exercise program through a planning process that DHS argues is adaptable to any
type of exercise scenario. Volume II provides a discussion of the various
components of designing and developing an exercise program. Broadly, the exercise
design process provided may be summarized as
! identifying the organization’s capabilities, tasks, and objectives;
! designing the scenario;
! developing exercise support documents (guides, handbooks and
situation manuals);
! coordinating logistics;
! planning how the exercise will be conducted; and
! selecting an evaluation and improvement methodology.
The HSEEP method guidance recommends that an exercise planning team, the
principal venue for exercise command and control, should be convened. The team
should be of manageable size, but representative of the full range of organizations
78 Available at [https://hseep.dhs.gov/support/VolumeI.pdf].
79 Available at [https://hseep.dhs.gov/support/VolumeII.pdf].
80 The HSEEP method identifies an “exercise foundation,” as the necessary precondition for
the exercise program. It consists of a base of support where all participants agree to the
importance of the exercise and understand the link between the purpose and objectives of
the exercise program and the strategic goals of the organization.
81 Available at [https://hseep.dhs.gov/support/VolumeIII.pdf].
82 Available at [https://hseep.dhs.gov/hseep_vols/HSEEP_Vol4/IVIntro.pdf].
83 The HSEEP method Volume II, Exercise Planning and Conduct, available at
[https://hseep.dhs.gov/support/VolumeII.pdf]. Unless noted otherwise, all material in this
section is drawn from the HSEEP method Volume II.

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and stakeholders participating in the exercise. The guidance suggests that this may
be accomplished by dividing the exercise planning team into five sections. These
sections include
! a command section that oversees exercise planning and activities;
! an operation section that provides for technical and functional
expertise;
! a planning section that develops exercise documentation, including
policies, procedures, and evaluations;
! a logistic section that provides material, supplies, services, and
facilities; and
! an administration and finance section that oversees the budget of the
exercise.
Exercise Evaluation: The HSEEP Method, Volume III. Volume III of
the HSEEP method, Exercise Evaluation and Improvement Planning,84 applies
“capabilities-based planning” for developing emergency preparedness and response
capabilities suitable for responding to a wide range of threats and hazards. The
HSEEP method uses a target capabilities list (TCL) from the National Preparedness
Guidelines developed by DHS85 to conduct initial exercise evaluation and analysis.
The TCL includes 37 identified capabilities distributed among capabilities common
to all response, and four specialized mission capabilities, including prevent, protect,
respond, and recover.86 Exercise capabilities are subjected to three levels of analysis:
84 The HSEEP method Volume III, Exercise Evaluation and Improvement Planning,
available at [https://hseep.dhs.gov/support/VolumeIII.pdf]. Unless noted otherwise, all
material in this section is drawn from the HSEEP method Volume III.
85 The TCL is available in U.S. Department of Homeland Security, Target Capabilities List:
A Companion to the National Preparedness Guidelines, Sept, 2007, available through the
Lessons Learned Information System (LLIS) to authorized users, at
[https://www.llis.dhs.gov/docdetails/details.do?contentID=26724]. The NPG is available at
[http://www.dhs.gov/xlibrary/assets/National_Preparedness_Guidelines.pdf].
86 In the TCL, common capabilities include planning; communications; community
preparedness and participation; risk management; and intelligence and information sharing
and dissemination. Prevent mission capabilities include information gathering and
recognition of indicators and warning; intelligence analysis and production; counter-terror
investigation and law enforcement; and chemical, biological, radiological, nuclear
explosives (CBRNE) detection. Protect mission capabilities include critical infrastructure
protection; food and agriculture safety and defense; epidemiological surveillance and
investigation; and laboratory testing. Respond mission capabilities include on-site incident
management; emergency operations center (EOC) management; critical resource logistics
and distribution; volunteer management and donations; responder safety and health;
emergency public safety and security; animal disease emergency support; environmental
health; explosive device response operations; fire incident response support; WMD and
hazardous materials; response and decontamination; citizen evacuation and shelter-in-place;
isolation and quarantine; search and rescue (land-based); emergency public information and
warning; emergency triage and pre-hospital treatment; medical surge; medical supplies
management and distribution; mass prophylaxis; mass care (sheltering, feeding and related
services); and fatality management. Recover mission capabilities include structural damage
(continued...)

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task-level analysis, activity-level analysis, and capability-level analysis. Other
components of exercise evaluation include the following:
Exercise Evaluation Guides (EEG). EEGS assist exercise evaluators by
providing them with a consistent set of standards and guidelines for data collection,
observation, analysis, and report writing. Information obtained through the EEG is
used to record the degree to which a prescribed task or performance measure was
accomplished during the exercise.
Debriefing. Immediately after an operations-based exercise, evaluators debrief
exercise players and controllers.87 This facilitated discussion, known colloquially as
a “hot wash,” allows players to engage in a self-assessment of their exercise play and
provide a general assessment of how the organization performed in the exercise.
Data analysis. Following the debriefing, evaluators review the notes of the
discussion and begin to develop preliminary analyses of the exercise, including the
development of a chronological narrative of each capability and associated activities.
From the notes, evaluators develop a draft after action report (AAR) that highlights
strengths and areas for improvement and identify discussion points relevant to an
organization’s ability to carry out the activities and demonstrate the capabilities being
exercised.
AAR/Improvement Plan (IP). An AAR articulates the observations of an
exercise and makes recommendations for post-exercise improvements. An IP
identifies specific corrective actions,88 assigns these actions to responsible parties,
and establishes target dates for action completion. The AAR and the IP are
distributed jointly as a single document.
After Action Conference. Members of the evaluation team, and other
members of the exercise planning team conduct an After Action Conference to
present, discuss, and refine the draft AAR. The conference serves as an opportunity
for entities that participated in the exercise to provide feedback and make necessary
changes to the AAR. Any corrective actions are assigned to a responsible person or
agency.
86 (...continued)
assessment; restoration of lifelines; and economic and community recovery. See DHS,
Target Capabilities List, p. vii, at [https://www.llis.dhs.gov/docdetails/
details.do?contentID=26724].
87 Larger exercises involving multiple agencies may feature a series of hot washes in which
smaller organizations, or smaller units of larger organizations, provide initial observations
and assessments of their exercise participation. The findings from these debriefings may
be forwarded to exercise commanders for incorporation into an exercise-wide AAR, and
may be retained by an agency for development of internal AARs, or as guidance in internal
improvement programs.
88 An improvement plan may also be identified by some agencies as a corrective action
program.

CRS-24
Finalization of the AAR/IP. Following the After Action Conference, the
exercise planning and evaluation teams finalize the AAR/IP. This involves
incorporating the corrections, clarifications, and other feedback provided by
participants at the After Action Conference
Track implementation. The HSEEP method guidance suggests that the
implementation of corrective actions identified in the final AAR/IP should be
assigned to exercise and emergency response personnel who participated in an
exercise.
DOD Exercise Evaluation
Exercise evaluations conducted by Department of Defense organizations will
typically be conducted in accordance with individual service or joint doctrine,
depending on whether the organization or activities being evaluated are service-
specific or multi-service. The HSEEP method is only used to evaluate interagency
activities. To illustrate this, the process used by USNORTHCOM to collect,
evaluate, and forward data to other agencies and the Joint Staff is outlined below.
The final paragraph addresses the unique situation of the National Guard.
One of the primary DOD organizations to participate in NLEs at the operational
level is USNORTHCOM. USNORTHCOM follows a structured process to evaluate
the command’s performance after both exercises and operations. During exercises,
observations and findings are collected by dedicated observers and from submissions
provided voluntarily by other exercise participants. The dedicated observers are
subject matter experts in the areas they are assigned to watch. Their task is to both
look for general “lessons” and to assess mission performance in order to help
commanders evaluate the quality of training received during an exercise. Observers
also validate the effectiveness of specific corrective actions implemented since the
last exercise or operational event. Exercise participants have access to a web-based
lessons-learned application that allows review of past lessons and entry of new
observations. USNORTHCOM holds “hot wash” meetings after major events to
discuss and consolidate lessons learned. For exercises, these are held after
completion of an exercise at a variety of levels before the commander and his or her
staff conduct a formal after action review. A “quick look” report is compiled within
30 days of exercise completion to describe the exercise and initial internal results.
A more comprehensive report, which includes observations and reports from
participating organizations, is compiled within 90 days of exercise completion.
Requests for corrective actions are coordinated through USNORTHCOM
headquarters where they are entered into a lessons-learned database, assigned an
Office of Primary Responsibility to implement necessary corrective action, and
tracked until all required corrective actions are completed. For findings that require
involvement of organizations outside USNORTHCOM, the headquarters will draft
and send a message to the involved agency requesting the action needed.89
89 Much of the information in this section was provided by USNORTHCOM Legislative
Affairs by e-mail to CRS on May 16, 2008.

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This information is also typically submitted to the Joint Lessons Learned
(JLLIS) Program Manager at the Joint Staff (J7) as well. DOD uses the JLLIS to
collect inputs from all of the Combatant Commands, as well as from the various
defense agencies, OSD and the Joint Staff. These inputs form the basis for
developing interagency lessons learned and requests for corrective action.
Interagency issues of a critical nature or which involve national policy or legislative
change are entered by J7 into the NEP CAP database and tracked accordingly. The
use of NEP CAP by DOD is still a relatively new process; the expectation is that it
will be utilized with greater frequency as the NEP matures.90
National Guard Exercise Evaluation. As noted previously, the National
Guard also plays a significant role in NLE events, but they typically participate in
their capacity as a state militia rather than as a federal reserve force. As such, they
operate under the control of their state governor rather than the Department of
Defense. This unique status introduces some ambiguity into methods by which
National Guard forces are evaluated during an NLE. Although they would normally
perform their assigned tasks in accordance with the Army or Air Force doctrine,91 or
joint doctrine if applicable, there are certain tasks that would likely be governed or
influenced by state guidance (for example, conducting law enforcement or search and
rescue activities). Moreover, it is unclear whether participating National Guard units
would be evaluated by state and local officials using the HSEEP method, by military
observers using service or joint doctrine, or both. The extent to which interagency
issues identified by these evaluations are entered into the NEP CAP database is also
unclear.
Discussion and Analysis
Official and scholarly post-exercise reviews suggest that some benefits result
from running preparedness exercises. It has been argued that the TOPOFF series has
improved preparedness, particularly at the state and community levels.92 Participants
in TOPOFF 4 in the Oregon venue indicate that the exercise experience was
particularly helpful when the state responded to a flooding incident a few weeks after
the FSE. The exercise offered emergency managers and responders an opportunity
to meet and interact, which facilitated, and in some cases expedited, incident
response.93 Other observers note that participation in TOPOFF 4 highlighted the
90 Much of the information in this section was provided by OSD Legislative Affairs by e-
mail to CRS on September 30, 2008.
91 In the case of the Army National Guard and the Air National Guard, respectively.
92 For example, challenges associated with the dissemination of vaccines have been
identified and subsequently revamped following bio-terrorism exercises. See Aaron Katz,
Andrea B. Saiti, and Kelly L. McKenzie, “Preparing for the Unknown, Responding to the
Known: Communities and Public Health Preparedness,” Health Affairs, vol. 25, no. 4
(July/August, 2006), pp. 947-948.
93 Oregon OEM, August 14, 2008.

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importance of emergency management to local officials.94 Two potential concerns
arise however, including 1) whether or how state and local preparedness grows in
localities that do not participate in TOPOFFs or future NLEs; and 2) how experiences
and knowledge gained from exercises lead to revision of the emergency plans of
participating jurisdictions.
Exercises strengthen core functions that contribute to the success of various
preparedness programs.95 For example, the nation’s medical and public health
system’s ability to respond to a bioweapons attack has been comprehensively tested
through the TOPOFF series, and, according to some observers, has provided several
lessons as to how it might respond to future epidemics.96 Further, collaborative
relationships which had not existed previously between different levels of
government and disparate agencies have developed during TOPOFF exercises. For
example, activities focused on bioterrorism have brought public health officials
together with emergency management, fire and police departments, and medical care
providers in active working relationships.
Exercise observers, planners and participants generally agree that exercise
experiences contribute to overall preparedness. Nevertheless, the evolution and
maturation of emergency preparedness doctrine as expressed in NRF, NIMS, NPG,
and the HSEEP method, and the emergence of NEP, may raise a number of questions
and issues that Congress might consider. These arise in three broad, interrelated
topical areas: National preparedness policy, exercise findings, and exercise
operations. National preparedness policy topics include the following:
! authorities under which NEP is created and managed;
! state, territorial, local, tribal and private sector participation in the
NEP;
! evaluating NEP progress;
! the status of the National Exercise Center;
! communicating preparedness policy; and
! congressional issues.
Exercise findings issues are not directly related to the NEP, but address matters
that have been identified through exercises, and which may inform considerations of
an array of policy areas related to preparedness. Exercise findings topics include the
following:
! surge capacity; and
! interstate movement of commercial emergency response vehicles.
Exercise operations topics incorporate a number of matters related to the
planning and conduct of exercises, including
94 Portland OEM, August 18, 2008.
95 Katz, Saiti, and McKenzie, “Preparing for the Unknown,” p. 950.
96 Thomas V. Inglesby, “Observations from the Top Off Exercise,” Public Health Reports,
vol. 116, supplement 2 (2001) p. 64.

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! realism in exercise scenarios and exercise play;
! the scale and scope of exercises;
! exercise evaluation concerns; and
! the status of existing exercise programs as NEP evolves.
National Preparedness Policy
Implementing Preparedness Exercise Programs: Which Authority?
The extent to which HSC, DHS, or FEMA exercise leadership on a national exercise
program incorporating federal, state, territorial, local, and tribal levels of
governments, as well as private sector actors, is unclear. Among other concerns, the
extent to which DHS has implemented the direction set out by Congress in the Post-
Katrina Emergency Management Reform Act, as well as whether the NEP advances
the state of preparedness of the government to respond effectively to emergency
management incidents, is at issue.
One challenge is the apparent conflation of authorities requiring preparedness
exercises. The NEP implementation plan attempts to integrate the mandates of two
authorities — one, a statute (the Post-Katrina Emergency Management Reform Act),
the other a presidential directive (HSPD 8) — while asserting that the “NEP shall
serve as the principal mechanism for (1) examining the preparedness of the USG and
its officers and other officials and (2) adopting policy changes that might improve
such preparation.”97 This statement implies the assertion of a third, executive-based
authority, either the NEP charter, or the NEP implementation plan itself. Broadly,
the focus of the NEP implementation plan could bring into question the extent to
which the Bush Administration is implementing exercise-relevant portions of the
Post-Katrina Emergency Management Reform Act and HSPD 8. The extent to which
the NEP will become a “single comprehensive exercise program,”98 may also be
questioned, since the NEP implementation plan states that the NEP is directed at
principals of federal agencies, and other, unspecified key officials to link
“appropriate National and regional ... exercises,” but does not explicitly incorporate
state, territorial, local, or tribal government participation. Finally, the assertion that
the NEP is the principal mechanism to adopt policy changes raises questions about
the role of Congress in the evaluation and development of emergency preparedness
exercise policy.
Further complicating understanding of the NEP is the Administration-mandated
integration of the HSPD 8-based exercise program, and provisions of the Post-
Katrina Emergency Management Reform Act, or some unspecified combination of
both, as “one key pillar of the overarching [NEP] framework” called “HSEEP.”
Provisions of paragraph 18 of HSPD 8 and section 648 of the Post-Katrina
Emergency Management Reform Act are similar, but some of the exercise parameters
mentioned in the statute do not appear to be incorporated into the NEP
implementation plan. For example, the Post-Katrina Emergency Management
Reform Act provisions requiring that exercises be designed to stress the National
preparedness system do not appear to receive consideration in the NEP
97 NEP implementation plan, p.1.
98 Ibid., p. 3.

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implementation plan. The implementation plan does mention a need to address the
unique requirements of populations with special needs,99 but does not define those
populations, or what measures might be necessary to exercise to ensure that they are
adequately served. Similarly, and discussed in greater detail below, the
Administration does not appear to be implementing exercises with limited notice to
participants, as required by the Post-Katrina Emergency Management Reform Act.
Implementing Preparedness Exercise Programs: Which Officials?
The NEP implementation plan explicitly acknowledges the authority of section 648
of the Post-Katrina Emergency Management Reform Act, and identifies the Secretary
of DHS as the official responsible for NEP exercise management. The conflated
implementation of the Post-Katrina Emergency Management Reform Act, and
HSPD-8 in the HSEEP exercise program, coupled with the apparent incorporation
of that program in a manner subordinate to the NEP, raises questions regarding the
FEMA Administrator’s ability to carry out statutory authority assigned to him by
Congress to carry out a National exercise plan.100 For example, how does the
implementation of HSPD-8 and the NEP implementation plan affect the FEMA
Administrator’s responsibilities to carry out a National exercise program, as directed
in the Post-Katrina Emergency Management Reform Act? To what extent are HSC,
NSC, or other DHS entities involved in NEP, HSEEP exercise program, or Post-
Katrina Emergency Management Reform Act planning and implementation? If
disputes arise among agencies, what decision making authority might the FEMA
Administrator exercise pursuant to his Post-Katrina Emergency Management Reform
Act authority? How might the Secretary of DHS balance authorities and mandates
conferred by the President with the statutory obligations assigned to the
Administrator?
Issues related to the role of the FEMA Administrator in the NEP may also
mirror more general concerns about the role of FEMA in DHS, or raise questions of
which government official is ultimately responsible for emergency preparedness.
Relatedly, managing NEP implementation through an interagency process led by a
cabinet-level entity or one of its subordinate components may also raise questions.
If the consensus on which much of the NEP decision making relies is not achieved,
what capacity does any official in DHS have to lead or compel the heads of other
federal executive agencies to comply with NEP-related directives? How might
leaders of executive agencies with exercise responsibility under their own authority
participate in NEP processes?
State, Territorial, Local, and Tribal Participation in the NEP. Some
observers assert that emergency preparedness response and recovery are basic tasks
of government at all levels of government, and that the very nature of a federalized
system of government itself poses significant challenges to developing and exercising
99 The Post-Katrina Emergency Management Reform Act, P.L. 109-295, sec. 648(b)(2)(v),
120 Stat. 1428 mandates that the exercises be designed to address the unique requirements
of populations with special needs. Beyond using the EEG to identify at risk populations, it
is unclear what is being done to address special needs populations.
100 The Post-Katrina Emergency Management Reform Act, P.L. 109-295, sec. 648.

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homeland preparedness plans.101 The NEP implementation plan is binding on the
federal executive branch but does not mandate exercise participation by sub-national
units of government. While the focus of NLEs is chiefly on federal strategies and
senior leader participation, future NEP Tier 1 and 2 exercises might require the
participation of state, territorial, and local governments. Moreover, the Post-Katrina
Emergency Management Reform Act requires national exercises to “test and evaluate
the readiness of Federal, State, local, and tribal governments to respond and recover
in a coordinated and unified manner to catastrophic incidents.”102 Despite this, the
NEP implementation plan is unclear how state, territorial, local, and tribal
governments might be integrated into NLEs, or other exercise components.
TOPOFF exercises were carried out in states that volunteered to participate,103
and which were selected by DHS. If practices used in the TOPOFF series continue
under the NEP, participation by states and municipal or tribal governments will likely
represent a significant commitment of their time and resources. Under funding
mechanisms used in previous TOPOFF exercises, DHS provided some direct funding
for state and municipal participation. Participants in TOPOFF 4, however, were
required to apply funds received through the Homeland Security Grant Program
(HSGP) and Urban Area Security Initiative (UASI)104 (which in some cases were
intended by recipients for other purposes),105 or to fund their participation with their
own resources. In the Oregon venue of TOPOFF 4, the City of Portland worked on
the exercise for two years prior to the FSE, and spent more than $10 million. Of that
total, UASI grants covered between $6 million and $8 million, leaving the city to pay
more than $2.5 million.106 It might be the case that some non federal participants
could choose not to participate in future NLEs if that participation would supplant
their ongoing emergency preparedness program, or if they lacked the resources to
fund their participation. A potential consequence could be that state, territorial, local
or tribal jurisdictions with the means to participate could develop more robust,
effective preparedness programs, while non participants could be less prepared to
respond to incidents in their areas of responsibility.
State and local participants in TOPOFF 4 also indicated concern about the
clarity of expectations and the extent of mutual agreement regarding those
101 See Christine E. Wormuth and Anne Witkowsky, Managing the Next Domestic
Catastrophe, pp. vi, 5-9.
102 Ibid., p. 3.
103 Portland OEM, August 18, 2008; and Oregon OEM August 16, 2008.
104 6 U.S.C. 321(a) allows DHS grants made to states or local or tribal governments HSGP
or UASI to conduct exercises of mass evacuation plans in the event of a natural disaster, act
of terrorism, or other man-made disaster. 6 U.S.C. 609(a)(2) allows DHS grants made to
states or local or tribal governments HSGP or UASI to be used to design, conduct, and
evaluate training and exercises, including national exercises. See CRS Report RL32348,
Selected Federal Homeland Security Assistance Programs: A Summary, by Shawn Reese.
105 At the time of the TOPOFF 4 planning and FSE phases, UASI and HSGP grant recipients
were required to apply grant resources to counter terrorism preparedness activities. Since
TOPOFF 4, funding options have broadened to incorporate an all-hazards orientation.
106 Portland OEM, August 18, 2008.

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expectations among local, state, national exercise planners and participants. Some
local participants noted that opportunities to collaborate with DHS during the
exercise design and development process were limited, with one observer describing
their office’s interactions as “more of a directive process,” with DHS providing the
direction.107 This may be of concern, since another participant noted that during
exercise play in the Oregon venue, federal participation, other than radiological
monitoring, was not required for the state to respond to the exercise scenario.108 State
and local participants in the Oregon venue also raised concerns that the memoranda
of understanding (MOU) governing expectations and responsibilities of the
participants and DHS were not finalized until the day FSE exercise play began, and
near the end of the period covered by the MOU.109 This may raise questions
regarding the utility of the exercise for some federal participants (See Exercise Scale,
below), as well as the extent to which DHS engages the input of state, territorial,
local and tribal entities regarding exercise planning that affect their jurisdictions. On
the other hand, the explicit focus on federal departments and agencies presented in
the NEP implementation plan110 may better communicate the intent of NLE activities
in a manner in which the TOPOFF series did not.
A related area of concern regarding intergovernmental interactions is that
preparedness doctrine requires that in an actual incident, municipalities respond first.
Responders and organizations on scene may request state or territorial support and
assistance, and states and territories may in turn request federal support. It is
questionable how those assumptions could be incorporated into preparedness
planning if exercises are planned in a manner that imposes a federal presence into
what are arguably exclusive local responder responsibilities.
Private Sector Participation. One TOPOFF 4 private sector participant
noted that the need to exercise response plans are not exclusive to the public sector
because “an emergency or disaster will affect us all.”111 Key resources and critical
infrastructures are in private hands. Small firms account for 85% of all U.S.
businesses, yet some critics claim that small businesses were left out of TOPOFF
exercises. These critics point out that manufacturing and distribution firms also need
to test their preparedness plans to make sure they are congruent with National
preparedness levels.112 Private sector participants in the TOPOFF 4 Oregon venue
107 Ibid.
108 Oregon OEM August 16, 2008.
109 Ibid., and Portland OEM, August 18, 2008.
110 NEP implementation plan, pp. 2-3.
111 CRS discussion with Doug McGillivray, TOPOFF 4 lead, Private Sector Working Group,
Portland, Oregon area, August 29, 2008 (hereafter McGillivray, Private Sector Working
Group), Portland OEM, August 18, 2008; and Oregon OEM August 16, 2008.
112 “DRI Calls for Small Firm Participation in Next TOPOFF Preparedness Drill”
Emergency Preparedness News, April 19, 2005.

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have suggested that during the planning phases, communications between private-
sector and government participants were sometimes challenging, or nonexistent.113
On the other hand it is arguable that TOPOFF 4 and future NLEs are chiefly
designed to exercise national strategic issues to test emergency response capacities
through national planning scenarios. Moreover, during the TOPOFF 4 FSE in the
Oregon venue, approximately 40 private sector entities participated, and private
sector observers were placed in state and county emergency operations centers (EOC)
to observe and relay exercise information to a DHS-funded private sector EOC for
transmission to interest private sector entities. At the same time, it has been asserted
that public sector exercise authorities were unaware, and did not seek to learn during
exercise play, of private sector capacities to provide technical and logistical support
in the exercise, and presumptively, in response to an incident. Further, during the
after action phase of TOPOFF 4, it has been asserted that private sector concerns
were “ignored or dismissed” by federal exercise officials.114 In its quick look AAR,
DHS identifies effectively integrating the private sector into some aspects of the
exercise response as an area for improvement, noting that “[t]here are many federal,
state, and local agencies with similar and overlapping responsibilities for private
sector coordination that appear to complicate private sector participation in response
and recovery activities.” The report also said that “the private sector was prepared
to be engaged and coordination improved later in the exercise.”115
Private sector participation in exercises may also occur at the national level.
AT&T, a communications holding company, through its representatives in the
National Coordinating Center for Telecommunications (NCC),116 “were engaged
throughout the planning phase and had significant input for the
cyber/communications components of the [TOPOFF 4] exercise through DHS and
its exercise contractors.” The company also deployed various response teams to
exercise venues. The firm notes that it did raise concerns related to TOPOFF 4, and
that while responses received through NCC “are a work-in-progress that do not
113 Kristen Hartwigsen, Senior Business Continuity Analyst, Nike, Inc., presentation at the
2008 DOD Defense Continuity and Crisis Management Conference, May 14, 2008, and in
discussion with CRS, August 14, 2008. Ms. Hartwigsen is also the founding director of the
Oregon Regional Emergency Network, and is a member of the Oregon State DHS Public
Private Subcommittee.
114 McGillivray, Private Sector Working Group, August 29, 2008.
115 Department of Homeland Security Top Officials 4 (TOPOFF 4) Full-scale Exercise
(FSE), After Action Quick Look Report, November 19, 2007, p. 8, available at
[http://www.fema.gov/pdf/media/2008/t4_after%20action_report.pdf].
116 According to its website [http://www.ncs.gov/ncc/],the NCC is component of the
National Communications System (NCS) which resides in DHS National Protection and
Programs. NCC is a joint government and industry structure and emergency response
capability that coordinates “the initiation, restoration, and reconstitution of United states
government national security and emergency telecommunications services.”

CRS-32
produce immediate results..., [p]artnering with government is a process, not a project,
which relies on relationships and mutual understanding.”117
Congress might inquire as to the extent to which private sector entities and
nongovernmental organizations (NGO) are involved in exercises carried out under
the NEP as well as the manner in which that participation affects preparedness
capacities.
Evaluating NEP Progress. The NEP implementation plan notes that
FY2007 and FY2008 “have and shall be devoted to attaining full operational
capability to support the NEP Concept of Operations,” and that various process
milestones were to be achieved before September 30, 2008. Process milestones
include the first implementation of the full NEP annual exercise programming
process, which began in Aug. 2007; DHS developed templates and guidance on NEP
products for consideration prior to June 30, 2007; and the first NEP Strategic
Exercise Guidance, that was to be issued in September 2008. Additionally, the NEP
implementation plan states that “all NEP support capabilities ... shall be fully
implemented no later than September 30, 2008, in time to support the first full NEP
strategic exercise cycle.”118 Did NEP reach those milestones? How were the
milestones developed?
National Exercise Simulation Center. Following Hurricane Katrina, the
Bush Administration recommended that DHS “develop and fund a National Exercise
Simulation Center [(NESC)] similar to” the DOD JWFC to “act as a tool to simulate
the Federal role in emergency response and be capable of working with State and
local exercises.”119 The Post-Katrina Emergency Management Reform Act requires
the President to “establish a national exercise simulation center that uses a
combination of live, virtual, and constructive simulations to prepare elected officials,
emergency managers, emergency response providers, and emergency support
providers at all levels of government ... to exercise decision making in a simulated
environment.”120 While not directly related to the NEP, the statutory mission of the
NESC appears to position it as a significant resource to support NEP goals. No
request for funding from DHS/FEMA, nor authorization or appropriation by
Congress for NESC for FY2008 and FY2009 was identified. In its FY2009
appropriation, DHS/FEMA received approximately $429 million for training,
technical assistance, exercises, and evaluations. Of that total, it appears that
approximately $70 million is available after other programs and initiatives have been
117 Email communication with Harry Underhill, Director, Critical Infrastructure Protection,
AT&T, August 19, 2008, hereafter, Underhill, AT&T email.
118 See NEP implementation plan, p. 21.
119 President George W. Bush, The Federal Response to Hurricane Katrina : Lessons
Learned (Washington: White House, 2006), p. 119, available at
[http://www.whitehouse.gov/reports/katrina-lessons-learned.pdf].
120 Post-Katrina Emergency Management Reform Act, P.L. 109-295, sec. 664, 120 Stat.
1433, 6 U.S.C. 764.

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funded.121 Through authorization, appropriations and other oversight processes,
Congress could inquire as to the status of the center, including whether it has been
established, or the extent of its development.
Communicating Preparedness Policy. In the past decade, national
preparedness policy has been expressed in a number of congressional and executive
branch policy statements and guidance documents. Among those documents are the
Homeland Security Act of 2002,122 Post-Katrina Emergency Management Reform
Act, National Strategy for Homeland Security,123 HSPD-5 on the management of
domestic incidents,124 HSPD-8, NPS, NRF, NPG, NIMS, the HSEEP method, and
NEP. Some documents are not readily available to officials and other interested
parties, raising questions of how effective they may be as a means of communicating
policy intentions. Some may conflict with others as the Post-Katrina Emergency
Management Reform Act and HSPD-8 appear to do. Others have not been updated
to reflect the introduction and integration of newer programs and policies, or refer to
documents or programs that have been superceded. For example, the HSEEP method
materials refer to the National Response Plan and the National Preparedness Goal,
which have been superceded by the NRF and NPG, respectively. On the HSEEP
method website, FEMA indicates that the “HSEEP [method] is compliant with, and
complements, several historical and current Federal directives and initiatives” but
does not include the Post-Katrina Emergency Management Reform Act.125 The
profusion of policy statements and guidance could lead to a lack of clarity of what
various preparedness initiatives are intended to accomplish, and which documents
communicate current requirements for response entities. Regarding exercises, it
could be argued that the lack of a clearly stated preparedness policy is constrained by
the lack of an explicit statement of how national preparedness priorities drive
exercise programs.
Congressional Interest. The development of a national emergency
preparedness exercise program through a federal executive interagency process
would appear to present Congress with a number of legislative and oversight options.
Government operations in the executive branch are generally overseen by the House
Committee on Oversight and Government Reform (OGR), and the Senate Committee
on Homeland Security and Governmental Affairs (HSGAC). OGR has jurisdiction
over government management measures, including the “management of government
121 See CRS Report RS22805, FY2009 Appropriations for State and Local Homeland
Security, by Shawn Reese.
122 P.L. 107-296, Homeland Security Act of 2002, 116 Stat. 2135, 6 U.S.C. 101.
123 Executive Office of the President, Office of Homeland Security, National Strategy for
Homeland Security, August, 2002, available at [http://www.whitehouse.gov/homeland/
book/nat_strat_hls.pdf].
124 Homeland Security Presidential Directive/HSPD-5, “Management of Domestic
Incidents,” available at [http://www.whitehouse.gov/news/releases/2003/02/
20030228-9.html].
1 2 5 S e e F E M A , H S E E P m e t h o d w e b s i t e , “ A b o u t H S E E P , ” a t
[https://hseep.dhs.gov/pages/1001_About.aspx].

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operations and activities,”126 which would appear to give it a role in emergency
preparedness and exercise oversight across the executive branch. The House
Committee on Homeland Security has both oversight and legislative responsibility
regarding the Department of Homeland Security, including “domestic preparedness
for and collective response to terrorism,” as well as “broad oversight authority over
government-wide homeland security matters.”127 In the Senate, the Committee on
Homeland Security and Governmental Affairs has jurisdiction over matters relating
to the Department of Homeland Security, with certain limitations,128 as well as
“organization and reorganization of the executive branch of the government.”129 This
would appear to give both panels some government-wide role in overseeing the
guidance and implementation of homeland security preparedness and exercises. At
the same time, it is arguable that other congressional committees could have authority
to oversee the preparedness and exercise activities of executive branch entities under
their jurisdiction.130
Exercise Findings Issues
Surge Capacity. A recurring deficiency revealed through TOPOFFs is
inadequate surge capacity. Many hospitals, police and fire departments cannot meet
the level of demand a disaster or large-scale emergency places on them.131
Maintaining facilities and staffing at a disaster level for long periods of time is
unlikely since it would be cost prohibitive for most organizations. At the same time,
a scalable response process capable of evolving with a disaster has not been
identified by public health practitioners. Overcoming surge capacities and related
workforce shortages may require additional funding or more creative resource
allocation practices to develop adequate capacity.
Interstate Movement of Commercial Emergency Response
Vehicles. During incident response, it is often necessary to deliver response
resources across state lines. One concern identified by private sector players in the
Oregon venue of TOPOFF 4 was the ability of commercial vehicles involved in
emergency response to travel into states in which they are not registered. Currently,
the Federal Motor Carrier Safety Administration (FMCSA) may waive certain federal
regulations (e.g., limiting hours of service) governing commercial vehicles during
126 House Rule X, cl. (1) (m) (6).
127 House Rule X, cl. (1) (i) (D).
128 CRS Report RS21955, S.Res. 445: Senate Committee Reorganization for Homeland
Security and Intelligence Matters, by Paul S. Rundquist and Christopher M. Davis. The
limitations do not appear to prevent the committee from exercising jurisdiction over Post-
Katrina Emergency Management Reform Act provisions underlying the NEP.
129 Senate Rule XXV (1) (k) (1) (10).
130 For example, the House or Senate Armed Services Committees could look into the
activities of DOD in the NEP.
131 See Katz, Saiti, and McKenzie, “Preparing for the Unknown,” p. 946.

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emergencies.132 State governors may waive certain state regulations governing
vehicles traveling in their jurisdictions (e.g., limitations on vehicle length and weight)
pursuant to their authorities.133 Federal and state waivers are typically issued for
limited periods of time, and apply only to vehicles involved in responding to a state
or federally declared emergency. Observers argue that the lack of common vehicle
standards from state to state, and the potential need to obtain waivers and proper
credentials for vehicles traveling through two or more states en route to an incident,
could impair the speed of emergency response.134 Congress might consider oversight
approaches that could define and address the extent of this potential challenge, or
legislative options that could address concerns that are identified.
Exercise Operations
Exercise Realism. While a goal may be to make an FSE as realistic as
possible, exercises usually must be run without interrupting routine day-to-day
operations135 or jeopardizing public safety. Some portions of some exercises must
be simulated to replicate the activities, decisions, policies and procedures of entities
that are unable to fully participate. While every effort is made to provide a realistic
environment in which to exercise, the necessity of simulating certain events or
actions, and the incomplete participation of assets that would respond to an actual
event, may have an impact on the ability to fully prepare participants, or to plan
corrective actions to incorporate into preparedness plans or future exercises. Further,
when exercise participants know that they are conducting an exercise, it may be that
players do not fully accept the premises of exercise play, or that the exercise
experience cannot replicate the stress and confusion that likely would accompany an
actual event. A lack of “real-world” connection in an exercise scenario could alter
the actions of exercise players. Similarly, an inability to shut down critical
infrastructures such as transportation or communications networks, public facilities,
or geographic regions during exercise play also may further compromise exercise
realism, and consequently, the lessons that might be drawn from them.
Another challenge may be that exercise processes interfere with the
preparedness of some participants. This could occur if exercise player are required
132 See 49 CFR 390.23. FMCSA waiver information is available at “Disaster Relief
Information for Drivers and Motor Carriers,” [http://www.fmcsa.dot.gov/
emergency/disaster-relief.htm].
133 State-issued waivers are posted on the “Notifications” section of the International
Registration Plan website at [http://www.irponline.org/Notifications/].
134 McGillivray, Private Sector Working Group, August 29, 2008.
135 During TOPOFF 4, for example, the Portland, Oregon Fire Bureau maintained full
staffing of its facilities. The department paid otherwise off-duty personnel to participate in
the exercise, but did not support round the clock exercise play, despite the near certainty that
fire assets would provide continuous response in an actual event. The fire bureau was one
of several entities that did not participate throughout the exercise. The response of non
participating entities was simulated when they were not available. Portland OEM, August
18, 2008; Oregon OEM August 16, 2008; State of Oregon, TOPOFF-4 after Action Report,
March, 2008, p. 54.

CRS-36
to carry out exercise management or coordination roles that are distinct from their
typical preparedness and response duties, or to assume agency leadership roles when
principals do not engage in exercise play. Similar concerns were raised by some
TOPOFF 4 participants, who noted that media inquiries about the exercise frequently
removed senior officials from the exercise.136 In either case, participants who carry
out exercise-specific duties may not have the benefits of exercising their incident
response responsibilities.137 Additionally, when agency leadership roles are
simulated, or played by officials who would not lead response to an actual incident,
the effectiveness of exercises as tools to enhance preparedness among officials with
principal response functions may be questioned.
No-Notice Exercises. Observers note that no-notice exercises “can provide
an accurate picture of how well the federal government can both coordinate the
actions of its own agencies and work collaboratively with state and local
governments in responding to a catastrophe.”138 The Post-Katrina Emergency
Management Reform Act requires that all national exercises be “carried out ... with
a minimum degree of notice to involved parties regarding the timing and details.”139
The NEP implementation plan, however, requires only one no-notice, Tier II federal
interagency exercise in each five-year strategic exercise cycle. Since many incidents
occur with little or no notice, it is arguable that failing to incorporate the element of
surprise into exercise planning could reduce the ability of response officials to carry
out exercises under more realistic conditions, or to deploy response resources in a
complex and dynamic incident. The inherent challenges to initiating resource-
intensive, government-wide exercises such as NLEs, however, lead many observers
to argue that no-notice provisions cannot be met due to the scale of an NLE and the
extensive staff support required from participating entities over a period of many
months. In particular, state, territorial, local, and tribal entities that wish to
participate in an NLE must allocate resources through their respective budget
processes well in advance of their participation, or risk disrupting the regular duties
of available first responders.140 Congress might examine the issue of no-notice
exercise training, in an effort to balance the demands of effective emergency
preparedness training on the one hand, and the challenges raised by incorporating
non-federal participants into broader exercise programs on the other.
Scale and Scope of Exercises. Related to the issue of realism is the scale
and scope of preparedness exercises. Some observers of the TOPOFF exercise series
claim that while the exercises provided useful insights and opportunities to improve
response plans, the scale, level of attention, and the costs of the exercises were
136 Portland OEM, August 18, 2008.
137 Based in part on comments made during the Eagle Horizon 08 (NLE 2-08 continuity
component) After Action Conference, June 17, 2008.
138 Christine E. Wormuth and Anne Witkowsky, Managing the Next Domestic Catastrophe,
p. 62.
139 Post Katrina Act, sec. 648(b)(2)(iii).
140 OSD briefing July 23, 2008; NGB briefing August 5, 2008; Portland OEM, August 18,
2008; and Oregon OEM August 16, 2008.

CRS-37
excessive.141 Some Oregon venue participants spent more that two years on TOPOFF
4 from initial planning through the preparation of AARs and implementation of
improvement plans. Focusing on the FSE, one exercise participant said
we believe exercises can be more effective when they are designed to meet more
focused objectives, targeted toward fewer participants, and shorter in duration.
Government seems to believe that exercises must include everyone and take at
least a week to conduct. We realize there may be benefits from being
all-inclusive but the result is less effective training than might be achieved
through more frequent, smaller exercises that are focused on specific groups....
This allows for the development of an exercise with a realistic scenario that
maximizes the value for the exercise participants.142
Concerns have also been expressed that exercise scenarios have been adapted
to allow some federal participants a place to participate within an exercise, with little
clear connection between their response capability and the stated goals, or underlying
scenario, of the exercise.143 Similar concerns could be raised about the NEP in
general, and NLEs in particular.
Exercise Fatigue. The NEP was developed in part to address the challenge
of “exercise fatigue.” Exercise fatigue is said to occur when multiple exercises
require ongoing demands on an entity’s limited time and resources. The NEP
implementation plan argues that the fatigue factor is exacerbated when exercise
activities do not contribute to appreciable improvements in intergovernmental
coordination, exercise policies, plans, or emergency response performance.144
Exercise fatigue may also be complicated by the perception that some of the 15
National Planning Scenarios, which arguably have a relatively low likelihood of
occurring, may receive more attention than scenarios based on events that occur with
greater frequency, but that are arguably less sensational. TOPOFF 4 participants
noted that the exercise scenario involving the explosion of a radiological dispersion
device (RDD) in the Portland, Oregon area was unrealistic, and that floods, such as
those experienced in Oregon after the TOPOFF 4 FSE, are more likely to necessitate
emergency response. The transition from the TOPOFF series, which Congress
required to focus on terrorism, to NLEs based on the NPS,145 which incorporates all
hazards, may address some of these concerns On the other hand, it could be argued
that preparedness training for less likely scenarios is necessary to build public
confidence, or due to the potential scope of disruption, and the high economic, social,
and political costs of not preparing if an incident were to occur.
Some observers and preparedness officials, focusing on the process of exercise
development, argue that exercises and the underlying scenarios may not be as
valuable as the planning process in which an exercise is developed. Observers assert
141 McGillivray, Private Sector Working Group, August 29, 2008.
142 Underhill, AT&T email, August 19, 2008.
143 Portland OEM, August 18, 2008; and ATF briefing, August 15, 2008.
144 NEP implementation plan, p. 1.
145 Portland OEM, August 18, 2008; and Oregon OEM August 16, 2008.

CRS-38
that this is due in part to behavior during an incident when “crisis plans rarely occupy
centre stage in the heat of the moment.”146 During the planning phase of an exercise,
preparedness officials assert that exercise participants may receive technical
assistance, critically examine their plans, or interact with other entities to develop
exercise response operations, which could contribute to preparedness,147 although the
extent of that contribution may be questionable if communications processes among
exercise participants are problematic.
Some have raised concerns that exercise scenarios based on relatively low-
likelihood incidents may overprepare responders for incidents that are rare, or have
never actually occurred, while underpreparing responders for more frequently
occurring events.148 At the same time, while there are likely differences in the
substantive response to an improvised nuclear device (IND), or other WMD, they are
also likely to require some of the same target capabilities as those required to respond
to a cyber attack, or natural disaster.149 As the NEP is more fully implemented,
Congress might consider the extent to which the NEP has incorporated the “all-
hazards” orientation of the Post-Katrina Emergency Management Reform Act into
its exercise schedule.
Evaluating Exercises. Exercises are designed in part to demonstrate
capabilities and to reveal areas of deficiency in emergency response. In some
military exercises, capabilities may be demonstrated, or deficiencies identified, by
“exercising to failure,”150 or thoroughly practicing a particular response until all of
its weaknesses are identified. While most civilian exercises are designed to test and
demonstrate response capabilities, they do not incorporate exercise to failure, despite
Post-Katrina Emergency Management Reform Act requirements that some exercises
be designed to stress the NPS. The identification of capabilities on which to build
or deficiencies through an evaluation process and the publication of some findings
through a public AAR, as required by the HSEEP method, may raise challenges if
exercise participants have not adequately exercised their plans, or are concerned
about potential consequences as a result of negative evaluations. As a result, there
may be incentives for some exercise planners to understate exercise objectives,
overstate the extent to which those objectives are met, or to downplay or omit
deficiencies that are identified. Any of those approaches arguably undermines the
effectiveness of exercises as tools to prepare for an incident, or to evaluate an entity’s
capacity to respond to an incident. Congress might inquire if omissions are occurring
146 Arjen Boin, Paul ‘t Hart, Eric Stern and Bengt Sundelius, The Politics of Crisis
Management: Public Leadership Under Pressure (Cambridge: Cambridge University Press,
2005), p.146-148.
147 DHS/FEMA briefing, June 12, 2008.
148 ATF briefing, August 15, 2008.
149 For example, it is likely that the response to a WMD or natural disaster incident would
include first responder services from police, fires, and emergency medical resources. Other
target capabilities that may be somewhat scenario neutral include law enforcement and
investigation, prevention, medical services, securing the scene of an incident, intelligence
sharing, and communications to the public.
150 NGB briefing, August 5, 2008.

CRS-39
in the exercise evaluation process, and the purposes of such omissions if they are
occurring.
Another area of potential concern is the nature of the exercise evaluation
process. The HSEEP method does not provide common benchmarks or metrics to
apply in the evaluation of an exercise. Moreover, under the HSEEP method,
exercises are typically evaluated by the same group that designs the exercise. This
approach, which extends beyond the NEP to any entity that uses the HSEEP method,
may be problematic if the evaluators fail to critically assess their own program.
Congress might inquire if self-evaluations inhibit the evaluator’s objectivity toward
the exercise, or whether exercises may need to be rigorously evaluated through an
external, independent evaluation process to gain more accurate insight into response
capabilities and deficiencies.151 Given the specialized nature of exercise
development, it is unclear whether qualified external evaluators would be readily
available to every entity that exercises.
It could be argued that the public dissemination of deficiencies through the AAR
process or the use of external evaluation may inform adversaries of potential
vulnerabilities. If that is the case, then Congress could consider methods to secure
exercise information and restrict its distribution to appropriate recipients. A model
of tiered distribution has been used by DHS to provide TOPOFF 4 after action
materials. This includes three separate “quick look”AARs, including versions for the
public,152 participants, and the broader responder community. A final draft AAR,
which will be provided to the head of a participating entity, has not been released at
the time of this writing. The current approach may have limited utility as a means
of communication: some state and local TOPOFF 4 participants, who developed their
own AARs, have not been provided with draft or final copies of the participant
version. The lack of access to exercise review materials could impair the
effectiveness of the HSEEP method evaluation process and create challenges for
exercise participants who wish to incorporate broad feedback into their exercise
improvement programs.
Relatedly, Congress might question the extent to which deficiencies identified
in exercises are addressed, and whether corrective actions are integrated into
emergency management planning documents and processes. For example, it has
been reported that a hurricane preparedness exercise known as “Hurricane Pam” held
in July 2004 identified many of the problems that occurred when Hurricane Katrina
struck New Orleans in August 2005.153 Despite the exercise findings, emergency
151 Zack Phillips, Disaster Drills: Practice Doesn’t Make Perfect,” Government Executive,
November 1, 2006, p. 36.
152 Department of Homeland Security Top Officials 4 (TOPOFF 4) Full-scale Exercise
(FSE), After Action Quick Look Report, November 19, 2007, available at
[http://www.fema.gov/pdf/media/2008/t4_after%20action_report.pdf].
153 Some of the challenges included difficulties organizing a mass evacuation, and providing
services to those who remained in the area affected by the storm. See U.S. Congress,
Senate, Committee on Homeland Security and Governmental Affairs, Hurricane Katrina:
A Nation Still Unprepared, 109th Cong.,., 2nd sess., S.Rept. 109-322 (Washington: GPO,
(continued...)

CRS-40
managers reportedly failed to incorporate exercise experiences into response plans.154
On the other hand, emergency management officials have argued that they did not
have sufficient funding to implement any of the findings from the Hurricane Pam
exercise into standing response plans.155 Congress might inquire as to the extent to
which the findings derived from exercises are being assimilated into emergency
planning and the nature and extent of impediments to such actions.
How “National” Is the NEP? The development of the NEP framework
appears to have brought DHS and DOD exercise planning and synchronization assets
together to establish a common, or at least collaborative, exercise scheduling process.
Exercise information relating to other agencies that staff the NEP executive steering
committee has not been identified. While this precludes their evaluation, their
participation in the DRG E&E Sub-PCC suggests an awareness of exercise planning
matters. It is unclear how information and expectations are communicated to federal
agencies that do not participate in the processes described in the NEP implementation
plan. As discussed above, the lack of a clear connection between the NEP and state,
territorial, local, and tribal government exercise programs may also raise questions
about the reach of the program.
NEP Opportunity Costs for Existing Agency Exercise Activities. In
various NEP presentations in 2006 and 2007, it was indicated that agency-level
exercise programs that do not necessarily fall under the NEP framework would
continue.156 The NEP charter asserts that the program shall not replace existing
federal executive agency exercise programs, but may incorporate agency-specific
exercises as needed.157 The NEP implementation plan, issued in 2008, however,
appears to provide ambiguous, potentially confusing guidance: “...NEP is intended
to provide a framework for prioritizing and focusing Federal exercise activities,
without replacing any individual department or agency exercise program”; “...NEP
incorporates HSEEP [exercise program] as well as other department and agency
exercise programs...”; and “[a]ll departments and agencies shall have an have an
exercise participation decision process that accords priority to NEP Tier I and Tier
153 (...continued)
2006), available at [http://www.gpoaccess.gov/serialset/creports/katrinanation.html].
154 Zack Phillips, Disaster Drills: Practice Doesn’t Make Perfect,” Government Executive,
November 1, 2006 p. 36.
155 See testimony of Michael D. Brown, former Undersecretary of Emergency Response and
Preparedness and FEMA Director, DHS before the Senate Committee on Homeland Security
an Governmental Affairs hearing, Hurricane Katrina: the Roles of the Department of
Homeland Security and Federal Emergency Management Agency Leadership, February 10,
2006, retrieved through nexis.com
156 See Department of Homeland Security, “National Exercise Program,” presentation at the
DOD Worldwide Joint Training and Scheduling Conference 2007-1 (WJTSC 07-1), Mar.
8, 2007; and Department of Defense, Joint Staff, “Exercise Synchronization Working
Group,” presentation at the DOD Worldwide Joint Training and Scheduling Conference
2006-2 (WJTSC 06-1), Oct. 2, 2006. Both presentations are available from the authors upon
request.
157 NEP charter, p. 4.

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II events.”158 The NEP implementation plan does not specify what “other department
and agency exercise programs” are incorporated. Consequently, the effect, if any, it
will have on agencies’ abilities to conduct exercises in addition to their NEP
responsibilities cannot be determined.
A possible consequence of mandating agency participation in the NEP is that
existing agency exercise programs may need to shift the focus of their activities to
internal exercises that prepare an agency to participate in NEP exercises. This
preparation may come at the cost of other exercise activities that an agency may be
required to complete, or otherwise deem important, but that either do not fall within
the purview of the NEP, or that are not exercised regularly through an NLE. This
may be of particular concern in two instances at the federal level. In the first
instance, some agencies may not integrate emergency response training and exercise
preparation into their day-to-day activities. If they are not included in NEP activities,
their capacity to respond to an incident may be impaired. In the second instance,
agencies with emergency support function (ESF)159 responsibility may be limited in
their ability to exercise with interagency partners because their Tier II exercise
nominations are not incorporated into the NEP, or the exercise scenario for an NLE
does not necessitate a response in their area of ESF responsibility.
A potential consequence might be that while the NEP establishes a government-
wide exercise program, the combination of limited government-wide exercises,
potential resource transfer from other preparedness or exercise programs to meet
NEP requirements, and the use of exercise scenarios for which some agencies have
no responsibility could result in a reduction in the opportunity for some agencies to
exercise all of their preparedness and response roles in a manner that could better
ensures an effective response to an incident.
158 Quotes taken from NEP implementation plan, pp. 2, 3, and 17.
159 According to FEMA, ESFs provide structure for coordinating federal interagency support
for a federal response to an incident. They are mechanisms for grouping functions most
frequently used to provide federal support to states and federal-to-federal support, both for
declared disasters and emergencies. ESFs include (1) transportation; (2) communications;
(3) public works and engineering; (4) firefighting; (5) emergency management; (6) mass
care, emergency assistance, housing, and human services; (7) logistics management and
resource support; (8) public health and medical services; (9) search and rescue; (10) oil and
hazardous materials response; (11) agriculture and natural resources; (12) energy; (13)
public safety and security; (14) long-term community recovery; and (15) external affairs.
For each ESF, one federal agency is assigned as coordinator with management oversight.
One or more agencies with significant authorities, roles, resources, or capabilities for a
particular function within an ESF may serve as a primary agency. Other agencies with
specific capabilities or resources that support the primary agency in executing the mission
of the ESF are assigned as support agencies. See FEMA, Emergency Support Function
Annexes: Introduction, available at [http://www.fema.gov/pdf/emergency/nrf/
nrf-esf-intro.pdf].

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Appendix A. National Level Preparedness
Exercise Mandates
This appendix classifies legislative and executive mandates to conduct National
level preparedness exercises based upon their level of specificity.160 Those
provisions explicitly mandating National level preparedness training exercises, or
exercises of a similar magnitude, are listed in Table 1. Provisions that require the
conduct of homeland security or other preparedness exercises, but do not explicitly
require such exercises to be conducted on a National level are listed in Table 2.
Table 1. Express Mandates to Conduct “National Level
Preparedness Exercises”
Citation
Description
6 U.S.C. § 317(c)(3)(B)
Requires the Administrator of FEMA to require
each Regional Administrator to participate as
appropriate in regional and national exercises.
6 U.S.C. § 748(b)(3)
Requires the Administrator of FEMA to perform
national exercises, at least biennially, to test and
evaluate the capability of federal, state, local, and
tribal governments to detect, disrupt, and prevent
threatened or actual catastrophic acts of terrorism,
especially those involving weapons of mass
destruction.
6 U.S.C. § 764
Requires the President to establish a national
exercise simulation center that uses a mix of live,
virtual, and constructive simulations to prepare
elected officials, emergency managers,
emergency response providers, and emergency
support providers at all levels of government.
42 U.S.C. § 300hh-
Requires the Secretary of HHS to conduct an
11(a)(3)(c)
initial test of the National Disaster Medical
System and subsequent periodic tests as the
Secretary deems appropriate.
Exec. Order No. 12656 §§
Establishes a national security emergency
104(e), 1701(9)
exercise program and requires the support of the
heads of all appropriate federal departments and
agencies. Also directs FEMA to coordinate the
planning, conduct, and evaluation of national
security emergency exercises.
160 Only provisions that continue to require the conduct of preparedness exercises are
included in this appendix. Provisions that exclusively applied to specific exercise events
that have already taken place, such as TOPOFF 2000 and TOPOFF 2, are not listed here.

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Citation
Description
Homeland Security
Directs the Secretary of DHS, in coordination
Presidential Directive 8
with other appropriate federal departments and
§ (18)
agencies, to establish a national program and a
multi-year planning system to conduct homeland
security preparedness-related exercises. Also
directs all federal departments and agencies that
conduct national homeland security
preparedness-related exercises to participate in a
collaborative, interagency process to designate
such exercises on a consensus basis and create a
master exercise calendar.
Homeland Security
Directs the Secretary of HHS to establish
Presidential Directive 21 §
standards and performance measures for state and
(23)(a)(ii)
local government countermeasure distribution
systems, including demonstration of specific
capabilities in tactical exercises in accordance
with the National Exercise Program.
National Security
Directs the Secretary of DHS to develop, lead,
Presidential Directive 51 §
and conduct a federal continuity training and
(16)(e)
exercise program, which shall be incorporated
into the National Exercise Program developed
pursuant to Homeland Security Presidential
Directive-8.
Table 2. General Mandates to Conduct Exercises
Citation
Description
6 U.S.C. § 124h(b)(3)-(11)
Requires the Secretary of DHS to conduct
tabletop and live training exercises to regularly
assess the capability of individual and regional
networks of state, local, and regional fusion
centers to integrate the efforts of such networks
with the efforts of DHS.
6 U.S.C. § 313(b)(2)(G)
Requires the Administrator of FEMA to
provide training and exercises necessary to
respond to a natural disaster, act of terrorism,
or other man-made disaster.
6 U.S.C. § 314(a)(2)
With respect to the Nuclear Incident Response
Team, requires the Administrator of FEMA to
conduct joint exercises and provide funding to
the Department of Energy or the
Environmental Protection Agency for
homeland security training and exercises.

CRS-44
Citation
Description
6 U.S.C. § 612(a)(4)(A)
Requires the Administrator of FEMA to ensure
that states and high-risk urban areas that
receive grants administered by DHS conduct or
participate in exercises under section 648(b) of
the Post-Katrina Act of 2006 [6 U.S.C. §
748(b)].
6 U.S.C. § 753(a)(1)(B)
Requires the President to ensure that each
federal agency with responsibilities under the
National Response Plan has organizational
structures that are assigned, trained, and
exercised for the missions of the agency.
6 U.S.C. § 753(a)(3)
Requires the President to ensure that each
federal agency with responsibilities under the
National Response Plan develops, trains, and
exercises rosters of response personnel to be
deployed when the agency is called upon to
support a federal response.
6 U.S.C. § 913
Directs the Secretary of the Department in
which the Coast Guard is operating to require
each high risk facility to conduct live or
full-scale exercises described in 33 C.F.R. §
105.220(c) not less frequently than once every
2 years.
6 U.S.C. § 1137(c)(7)
Requires the Secretary of DHS to develop and
issue regulations for a public transportation
security training program, that will include,
among other things, live situational training
exercises regarding various threat conditions,
including tunnel evacuation procedures.
6 U.S.C. § 1167(c)(8)
Requires the Secretary of DHS to develop and
issue regulations for a railroad security training
program, that will include, among other things,
live situational training exercises regarding
various threat conditions, including tunnel
evacuation procedures.
6 U.S.C. § 1184(c)(8)
Requires the Secretary of DHS to develop and
issue regulations for an over-the-road bus
security training program, that will include,
among other things, live situational training
exercises regarding various threat conditions,
including tunnel evacuation procedures.

CRS-45
Citation
Description
49 U.S.C. § 44918(a)(2)(G)
Requires each air carrier providing scheduled
passenger air transportation to carry out a
training program for flight and cabin crew
members to prepare the crew members for
potential threat conditions, including
situational training exercises regarding various
threat conditions.
50 U.S.C. § 2315(a)(2)
Requires the Secretary of Homeland Security
to develop and carry out a program for testing
and improving the responses of federal, state,
and local agencies to emergencies involving
nuclear, radiological, biological, and chemical
weapons and related materials. The program
shall include exercises to be carried out in
accordance with sections 102(c) and 430(c)(1)
of the Homeland Security Act of 2002 [6
U.S.C. §§ 112(c), 238(c)(1)].

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Appendix B. Acronym Glossary
Acronym
Term
AAR
After Action Report
APHS/CT
Assistant to the President for Homeland Security and
Counterterrorism
APNSA
Assistant to the President for National Security Affairs
ATF
Bureau of Alcohol, Tobacco, Firearms and Explosives
CAP
Corrective Action Plan
CBRNE
Chemical, Biological, Radiological, and Nuclear
Explosives
CEP
Chairman (Of the Joint Chiefs of Staff) Exercise
Program
CFR
Code of Federal Regulations
CJCS
Chairman of the Joint Chiefs of Staff
CJCSI
Chairman of the Joint Chiefs of Staff Instruction
CJCSM
Chairman of the Joint Chiefs of Staff Manual
COOP
Continuity of Operations
CPX
Command Post Exercise
CRAF
Civil Reserve Air Fleet
CRS
Congressional Research Service
DHS
Department of Homeland Security
DNI
Director of National Intelligence
DOD
Department of Defense
DOJ
Department of Justice
DRG E&E Sub-PCC
White House Domestic Response Group, Exercise and
Evaluation Policy Coordinating Subcommittee
DSCA
Defense Support to Civil Authorities
EEG
Exercise Evaluation Guides
EOC
Emergency Operations Center (used generically)
ESC
Executive Steering Committee

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Acronym
Term
ESF
Emergency support Function
FE
Functional Exercise
FE
Functional Exercise
FEMA
Federal Emergency Management Agency
FMCSA
Federal Motor Carrier Safety Administration
FOUO
For Official Use Only
FR
Federal Register
FSE
Full Scale Exercise
HHS
Department of Health and Human Services
HSC
Homeland Security Council
HSEEP method
Homeland Security Exercise and Evaluation Program.
Exercise design, development, conduct, evaluation, and
improvement planning methodology.
HSGAC
Senate Committee on Homeland Security and
Governmental Affairs
HSGP
Homeland Security Grant Program
HSPD
Homeland Security Presidential Directive
IED
Improvised Explosive Device
IND
Improvised Nuclear Device
IP
Improvement Plan
J7
Joint Chiefs of Staff Operational Plans and Joint Force
Development directorate
JCS
Joint Chiefs of Staff
JEP
Joint Exercise Program
JFO
Joint Field Office
JLLIS
Joint Lessons Learned Program, DOD
JWFC
Joint Warfighting Center
LLIS
Lessons Learned Information Sharing,
[https://www.llis.dhs.gov]
MOU
Memorandum of Understanding

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Acronym
Term
NCC
National Coordinating Center for Telecommunications
NCP
National Continuity Programs
NCR
National Capital Region
NCS
National Communications System
NEP
National Exercise Program
NEXS
National Exercise Schedule
NGB
National Guard Bureau, DOD
NGO
Nongovernmental Organization
NGO
Nongovernmental Organization
NIC
National Integration Center, FEMA
NIMS
National Incident Management System
NLE
National Level Exercise
NOC
National Operations Center
NORAD
North American Aerospace Defense Command
NPG
National Preparedness Guidelines
NPS
National Planning Scenarios
NRF
National Response Framework
NRP
National Response Plan (superseded by NRF)
NSC
National Security Council
NSPD
National Security Presidential Directive
OEM
Office of Emergency Management (used generically)
OGR
House of Representatives Committee on Oversight and
Government Reform
OMB
Office of Management and Budget
OSD
Office of the Secretary of Defense
PI
Pandemic Influenza
PLE
Principal Level Exercise
POC
Point of Contact

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Acronym
Term
RDD
Radiological Dispersal Device
RDD
Radiological Dispersal Device
REP
Radiological Emergency Preparedness Exercise
TCL
Target Capabilities List
TOPOFF
Top Officials Exercises
TTX
Table Top Exercise
UASI
Urban Area Security Initiative
USAF
United States Air Force
USG
U.S. Government
USNORTHCOM
U.S. Northern Command
USTRANSCOM
U.S. Transportation Command
UTL
Universal Task List
WJTSC
World Wide Joint Training and Scheduling Conference
WMD
Weapon of Mass Destruction